Green v. Commissioner
United States Tax Court
An employee, who maintained a den in his Long Island residence where he chose for reasons of personal convenience to do work for his employer in the evenings, deducted automobile expenses incurred in driving between his home and his Manhattan office, stopping first at various clients' Manhattan offices. Held, petitioner's transportation expenses between his Long Island home and his Manhattan clients' offices and return were nondeductible commuting expenses.
1Opinion of the Court
Hall, Judge:
Tbe Commissioner determined a $406.33 deficiency in petitioners’ 1967 Federal income tax.
The sole issue is whether automobile expenses incurred by Thomas J. Green, Jr. (petitioner), in driving between his Long Island residence and his Manhattan business office via various clients’ Manhattan offices on 80 specific days in 1967 are deductible business expenses.1
FINDINGS OF FACT
All of the facts have been stipulated, and the stipulation of facts and exhibits attached thereto are incorporated herein by reference.
Petitioners are husband and wife, and resided in Port Washington, Long…
2Cases cited9 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Towne v. EisnerSupreme Court of the United States · 1918
- Dixon v. United StatesSupreme Court of the United States · 1965
- William W. Steinhort and Mildred Steinhort v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- A. G. Spalding & Bros. v. EdwardsSupreme Court of the United States · 1923
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3Cited by91 opinions
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Curphey v. CommissionerUnited States Tax Court · 1980
- CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
- Zimmerman v. CommissionerUnited States Tax Court · 1978
- Wisconsin Psychiatric Services, Ltd. v. CommissionerUnited States Tax Court · 1981
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