Puckett v. Commissioner
United States Tax Court
The petitioner was the postmaster of the LaVergne, Tenn., Post Office and an officer in the Tennessee National Guard. During 1967, he spent approximately 5 months on military duty at the Reserve Officers Training School at Fort Knox, Ky. While on such military duty, he continued to be responsible for the proper operation of the post office and returned to LaVergne each weekend for that purpose.
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The petitioner was the postmaster of the LaVergne, Tenn., Post Office and an officer in the Tennessee National Guard. During 1967, he spent approximately 5 months on military duty at the Reserve Officers Training School at Fort Knox, Ky. While on such military duty, he continued to be responsible for the proper operation of the post office and returned to LaVergne each weekend for that purpose. Held, the petitioner is not entitled to deduct his expenses for meals and lodging while at Fort Knox, because he has failed to provide the required substantiation for such expenses or to show that they…
1Dissent
Bruce, /.,
dissenting: I disagree with the opinion of the majority in two major respects.
First. — The majority has denied the petitioners a deduction for lodging expenses incurred by the petitioner Arthur 0. Puckett, Jr., while attending a Reserve Officers Training School of the U.S. Army at Fort Knox, Ky., in 1967, on the ground that “the quarters allowance” received by him while attending the Reserve Officers Training School “was to reimburse him for his lodging expenses during such service.” In my opinion, for the reasons hereinafter more fully discussed, the quarters allowance received by…
2Cases cited14 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Commissioner v. StidgerSupreme Court of the United States · 1967
- Bercaw v. CommissionerCourt of Appeals for the Fourth Circuit · 1948
- O'Hara v. CommissionerUnited States Tax Court · 1946
- Blum v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
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