Legal Opinion
Bernard v. United States
United States Court of Claims
Decided December 31, 1986No. 205-84 TPublishedCited by 2 opinions
1Opinion of the Court
OPINION
SMITH, Chief Judge.
Plaintiff, Michael J. Bernard (“taxpayer”), brought suit in this court seeking a $15,432.38 tax refund. On taxpayer’s 1979 and 1980 tax returns, he claims business deductions for entertainment, gifts, travel, meals, lodging, home as office, telephone, accounting, and licensing expenses all of which he incurred in his capacity as sales representative or as sales manager. The Internal Revenue Service (the “IRS”) disallowed these deductions in their entirety. Most of these deductions were said to be unsubstantiated. See I.R.C. § 274(d) (1976). Taxpayer’s travel expenses…
2Cases cited12 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- United States v. CorrellSupreme Court of the United States · 1967
- Cam F. Dowell, Jr., Evelyn Dowell and Hillcrest State Bank, Plaintiffs v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Robert Rosenspan v. United StatesCourt of Appeals for the Second Circuit · 1971
- Lee E. Coombs and Judy B. Coombs v. Commissioner of Internal Revenue, James C. Cox v. United StatesCourt of Appeals for the Ninth Circuit · 1979
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3Cited by2 opinions
- Bernard v. United StatesUnited States Court of Claims · 1987
- HeapeUnited States Tax Court · 1992