Walker v. Commissioner
United States Tax Court
P, a logger, drove daily from his residence to numerous job sites located throughout the Black Hills National Forest. P worked approximately 6 to 7 hours per day cutting trees. He also worked 7 hours per week at his residence on tool repairs and maintenance. P stored his equipment and supplies and took calls for jobs at his residence as well.
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P, a logger, drove daily from his residence to numerous job sites located throughout the Black Hills National Forest. P worked approximately 6 to 7 hours per day cutting trees. He also worked 7 hours per week at his residence on tool repairs and maintenance. P stored his equipment and supplies and took calls for jobs at his residence as well. R allowed 60 percent of P's vehicle-related expenses, which represented expenses for driving between job sites during the day and for trips to obtain supplies and repairs. R disallowed the remaining 40 percent of P's vehicle-related expenses, which…
1Opinion of the Court
Ruwe, Judge:
This matter was heard by Special Trial Judge Joan Seitz Pate pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 An opinion in this case was filed on July 15, 1993, Walker v. Commissioner, T.C. Memo. 1993-311. It was subsequently withdrawn and reassigned to this Division for reconsideration. The Court agrees with and adopts the findings of fact of the Special Trial Judge. The Court also agrees with and adopts the Special Trial Judge’s opinion holding that petitioner Charles W. Walker was self-employed during the years in issue and that payments to him, which were…
2Cases cited27 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- United States v. SilkSupreme Court of the United States · 1947
- Sanford v. CommissionerUnited States Tax Court · 1968
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3Cited by24 opinions
- Rauenhorst v. Comm'rUnited States Tax Court · 2002
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- Joly v. CommissionerUnited States Tax Court · 1995
- Beale v. CommissionerUnited States Tax Court · 2000
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