Tyler v. Commissioner
United States Tax Court
In 1942 petitioner, a pilot employed by United Air Lines in Seattle, accepted employment with a firm in Cleveland, which employment was thought at first to be temporary but continued until November 1, 1946. Petitioner's former employer from time to time from 1942 to May 1944 granted petitioner leaves of absence in order that he might retain his seniority rights as a pilot with United.
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In 1942 petitioner, a pilot employed by United Air Lines in Seattle, accepted employment with a firm in Cleveland, which employment was thought at first to be temporary but continued until November 1, 1946. Petitioner's former employer from time to time from 1942 to May 1944 granted petitioner leaves of absence in order that he might retain his seniority rights as a pilot with United. On March 30, 1945, petitioner's wife left him, taking with her various assets, including U. S. savings bonds jointly owned by petitioner and his wife and valued at $ 14,325. Held: (1) That the petitioner's…
1Opinion of the Court
OPINION.
ARUNdell, Judge:
Three principal issues are raised in this proceeding: First, the deduction as traveling expense in 1942 and 1943 of the cost of petitioner’s plane fare from Seattle to Cleveland and the cost of his meals and lodging while in Cleveland during those years; second, the deductibility of certain so-called entertainment expenses paid during the years 1942, 1943, and 1945; and, third, the deduction as a theft or embezzlement of a sum equal to the value of certain bonds jointly held by petitioner and his wife which the latter appropriated to her own use.
The first issue we…
2Cases cited4 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- O'Hara v. CommissionerUnited States Tax Court · 1946
- Bark v. CommissionerUnited States Tax Court · 1946
- Chapman v. CommissionerUnited States Tax Court · 1947
3Cited by5 opinions
- Walliser v. CommissionerUnited States Tax Court · 1979
- Ungar v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- Sanocki v. CommissionerUnited States Tax Court · 1989
- Tyler v. CommissionerUnited States Tax Court · 1949
- Walliser v. CommissionerUnited States Tax Court · 1979