Legal Opinion

Carney v. Commissioner

United States Tax Court

Decided February 23, 1978No. Docket No. 10548-75Unpublished

H, a camouflage engineer, and W spent 38 days visiting 8 European countries. Held, the major portion of such trip did not directly maintain or improve skills required in H's employment, and therefore, his portion of the expenses is not deductible.

1Opinion of the Court

JAMES RONALD CARNEY and ANNE CAMERON CARNEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Carney v. Commissioner

Docket No. 10548-75.

United States Tax Court

T.C. Memo 1978-71; 1978 Tax Ct. Memo LEXIS 444; 37 T.C.M. (CCH) 349; T.C.M. (RIA) 780071;

February 23, 1978, Filed

H, a camouflage engineer, and W spent 38 days visiting 8 European countries. Held, the major portion of such trip did not directly maintain or improve skills required in H's employment, and therefore, his portion of the expenses is not deductible.

James Ronald Carney, pro se.

Harris J. Belinkie and Thomas C. Morrison,…

2Cases cited5 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Marlin v. CommissionerUnited States Tax Court · 1970
  3. Gino v. CommissionerUnited States Tax Court · 1973
  4. George W. Gino and Emilie R. Gino v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
  5. Thomas P. Dennehy v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1962

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