Noyce v. Commissioner
United States Tax Court
P's position as vice chairman of Intel Corporation required frequent and extensive travel. By virtue of P's use of his private airplane, he was able to increase the number of meetings he could attend on behalf of Intel. Pursuant to Intel's policies, employee air travel was reimbursable only to the extent of commercial coach rates. Also as a matter of corporate policy, Intel officers were expected to bear certain travel expenses without reimbursement.
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P's position as vice chairman of Intel Corporation required frequent and extensive travel. By virtue of P's use of his private airplane, he was able to increase the number of meetings he could attend on behalf of Intel. Pursuant to Intel's policies, employee air travel was reimbursable only to the extent of commercial coach rates. Also as a matter of corporate policy, Intel officers were expected to bear certain travel expenses without reimbursement. R disallowed deductions P claimed for depreciation and expenses related to using the airplane in his employment with Intel. Held: P's use of his…
1Opinion of the Court
RUWE, Judge:
Respondent determined a deficiency in petitioners’ Federal income taxes for 1983 in the amount of $68,633.50. The issues for decision are: (1) Whether petitioners may deduct operating expenses and depreciation with respect to use of an airplane by Mr. Noyce in his capacity as a corporate official; (2) whether petitioners are entitled to deduct the airplane expenses and depreciation with respect to its use for Mr. Noyce’s flight training; (3) whether petitioners are entitled to deduct expenses and depreciation for flight time related to airplane maintenance; (4) what is the total…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- United States v. CorrellSupreme Court of the United States · 1967
- Commissioner v. TellierSupreme Court of the United States · 1966
- Bell v. New JerseySupreme Court of the United States · 1983
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3Cited by26 opinions
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- Avery v. CommissionerUnited States Tax Court · 1993
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