Jones v. Commissioner
United States Tax Court
Pursuant to an incentive program maintained by his employer, Mobil, petitioner was granted a 3-year release from status as an active employee at Mobil's laboratory in Dallas, Tex., to undertake studies at Ohio State University in Columbus, Ohio. During the entire period of his enrollment at Ohio State petitioner remained an employee of Mobil. Held, no part of the expenses for petitioner's meals and lodging while he was residing in Columbus is deductible.
Read the full summary
Pursuant to an incentive program maintained by his employer, Mobil, petitioner was granted a 3-year release from status as an active employee at Mobil's laboratory in Dallas, Tex., to undertake studies at Ohio State University in Columbus, Ohio. During the entire period of his enrollment at Ohio State petitioner remained an employee of Mobil. Held, no part of the expenses for petitioner's meals and lodging while he was residing in Columbus is deductible. Held, further, unreimbursed expenses incurred by petitioner in moving his family from Dallas to Columbus in 1963 are not deductible under…
1Opinion of the Court
OPINION
Petitioner has now conceded, in light of the Supreme Court’s recent decision in Bingler v. Johnson, 394 U.S. 741 (1969), that the bimonthly payments he received from Mobil while he was enrolled in Ohio State did not constitute a fellowship grant within the meaning of section 117 and that he continued to be an employee of Mobil during that time. Thus, since respondent did not disallow the deductions claimed for the direct expenses (for fees, tuition, books, etc.) incurred by petitioner at Ohio State or for the expenses of moving his family from Columbus to Dallas in 1966, we are left…
2Cases cited16 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Peurifoy v. CommissionerSupreme Court of the United States · 1958
- Kroll v. CommissionerUnited States Tax Court · 1968
- Commissioner of Internal Revenue v. James E. Peurifoy, Paul v. Stines and Betty O. Stines, John S. Hall and Doris D. HallCourt of Appeals for the Fourth Circuit · 1958
- Leo C. Cockrell, and Carol P. Cockrell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
11 more not listed; retrieve them via the Exa API.
3Cited by74 opinions
- Norwood v. CommissionerUnited States Tax Court · 1976
- Nico v. CommissionerUnited States Tax Court · 1977
- Rambo v. CommissionerUnited States Tax Court · 1978
- A. J. Michel, Jr. And Raymonde A. Michel v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1980
- Hartung v. CommissionerUnited States Tax Court · 1970
69 more not listed; retrieve them via the Exa API.