Mitnick v. Commissioner
United States Tax Court
Upon the facts, held (1) petitioner has not established that he had any "home" within the meaning of section 23 (a) (1) (A), Internal Revenue Code, and his traveling expenses for the years 1942, 1943, and 1944, therefore, were personal expenses and not deductible, and (2) petitioner has not sustained his burden of proof as to other expenses for which he claimed deductions for those years.
1Opinion of the Court
OPINION.
Hill, Judge:
Respondent contends petitioner should not be allowed any deductions for the expenditures involved for the reasons (1) that petitioner has not established any “home” within the meaning of section 23 (a) (1) (A) of the Internal Revenue Code,1 and, therefore, disbursements that he made while on the road with the shows were personal expenses and not deductible (sec. 24 (a)); and (2) that he has failed to sustain his burden of proof with respect to the amount of the deductions claimed. Petitioner claims that he has proved both a home within the meaning of section 23 (a) (1) (A)…
2Cases cited1 opinion
- Gustafson v. CommissionerUnited States Tax Court · 1944
3Cited by30 opinions
- Hicks v. CommissionerUnited States Tax Court · 1966
- Kershner v. CommissionerUnited States Tax Court · 1950
- Wilson John Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Johnson v. CommissionerUnited States Tax Court · 1952
- Smith v. CommissionerUnited States Tax Court · 1954
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