Legal Opinion

Hamblen v. Commissioner

United States Tax Court

Decided January 20, 1982No. Docket No. 3147-81Published

P, a minister of the Calvary Bible Church, regularly performed some of his ministerial duties in an office in his home. In 1976, he made daily round trips by automobile from his home office to his church office, which was his principal place of work. He deducted the costs of such transportation as a business expense under sec. 162(a), I.R.C. 1954. Respondent disallowed the claimed deduction.

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P, a minister of the Calvary Bible Church, regularly performed some of his ministerial duties in an office in his home. In 1976, he made daily round trips by automobile from his home office to his church office, which was his principal place of work. He deducted the costs of such transportation as a business expense under sec. 162(a), I.R.C. 1954. Respondent disallowed the claimed deduction. Held, in these circumstances, such transportation costs constitute commuting expenses which are personal and nondeductible.

1Opinion of the Court

Frank R. and Mary Jane Hamblen, Petitioners v. Commissioner of Internal Revenue, Respondent

Hamblen v. Commissioner

Docket No. 3147-81

United States Tax Court

78 T.C. 53; 1982 U.S. Tax Ct. LEXIS 147; 78 T.C. No. 4;

January 20, 1982, Filed

Decision will be entered for the respondent.

P, a minister of the Calvary Bible Church, regularly performed some of his ministerial duties in an office in his home. In 1976, he made daily round trips by automobile from his home office to his church office, which was his principal place of work. He deducted the costs of such transportation as a business expense…

2Cases cited13 opinions

  1. Fausner v. CommissionerSupreme Court of the United States · 1973
  2. William W. Steinhort and Mildred Steinhort v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
  3. United States v. John Paul MalinowskiCourt of Appeals for the Third Circuit · 1973
  4. Curphey v. CommissionerUnited States Tax Court · 1980
  5. Green v. CommissionerUnited States Tax Court · 1972

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