Legal Opinion

Haberkorn v. Commissioner

United States Tax Court

Decided November 12, 1980No. Docket No. 15361-79PublishedCited by 2 opinions

Held, P's mini-motorhome which provides living facilities is a "dwelling unit" within the meaning of sec. 280A(f)(1)(A), I.R.C. 1954, as amended.

1Opinion of the Court

OPINION

Tietjens, Judge:

Respondent determined a deficiency of $156 in petitioners’ Federal income tax for 1977. Since petitioners have conceded a reduction of $31 in their deduction for employee business expenses, the only issue is whether petitioners’ mini-motorhome is a “dwelling unit” within the meaning of section 280A(f)(l)(A)1 and, therefore, subject to the limitations imposed under section 280A(a).

This case was fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts and exhibits are incorporated herein by reference.

Petitioners timely…

2Cases cited3 opinions

  1. Federal Crop Ins. Corp. v. MerrillSupreme Court of the United States · 1947
  2. Utah Power & Light Co. v. United StatesSupreme Court of the United States · 1917
  3. Peek v. CommissionerUnited States Tax Court · 1980

3Cited by2 opinions

  1. Dellward Jackson v. CirCourt of Appeals for the Ninth Circuit · 2017
  2. Haberkorn v. CommissionerUnited States Tax Court · 1980

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API