Legal Opinion

Cooper v. Commissioner

United States Tax Court

Decided February 28, 1977No. Docket Nos. 3164-75, 6401-75PublishedCited by 26 opinions

Held, petitioner is entitled to deduct certain expenses incurred as a condition of his employment as ordinary and necessary business expenses under sec. 162(a), I.R.C. 1954.

1Opinion of the Court

Fay, Judge:

Respondent determined deficiencies in petitioner’s Federal income tax as follows:

Year Deficiency

1972. $92

1973. 96

Due to concessions, the sole issue remaining is whether certain expenses incurred by petitioner during the years in issue are deductible under section 162(a)1 as ordinary and necessary business expenses.

FINDINGS OF FACT

Some facts were stipulated and are so found.

Petitioner Robert E. Cooper resided in Van Nuys, Calif., at the time his petition was filed.

During the years in issue petitioner was employed as a fireman by the Los Angeles Fire Department and was assigned to…

2Cases cited8 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Kroll v. CommissionerUnited States Tax Court · 1968
  3. Primuth v. CommissionerUnited States Tax Court · 1970
  4. Drill v. CommissionerUnited States Tax Court · 1947
  5. Roth v. CommissionerUnited States Tax Court · 1952

3 more not listed; retrieve them via the Exa API.

3Cited by26 opinions

  1. Lee E. Coombs and Judy B. Coombs v. Commissioner of Internal Revenue, James C. Cox v. United StatesCourt of Appeals for the Ninth Circuit · 1979
  2. Sibla v. CommissionerUnited States Tax Court · 1977
  3. Moss v. CommissionerUnited States Tax Court · 1983
  4. Duggan v. CommissionerUnited States Tax Court · 1981
  5. Pollei v. CommissionerUnited States Tax Court · 1990

21 more not listed; retrieve them via the Exa API.

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