Legal Opinion

Warner v. Commissioner

United States Tax Court

Decided March 28, 1978No. Docket No. 10435-76PublishedCited by 9 opinions

Held, that expenses for transporting petitioner's son between her household and a child day care center are not deductible under sec. 214, I.R.C. 1954. Sec. 1.214A-1(c)(3)(i), Income Tax Regs., is valid.

1Opinion of the Court

OPINION

Dawson, Judge:

Respondent determined a deficiency of $98.80 in petitioner’s Federal income tax for the year 1974. The only issue presented for decision is whether the petitioner is entitled to deduct under section 214, I.R.C. 1954,1 expenses of $520 incurred by her during 1974 for the transportation of her preschool-age son between her household and the Blue Ash Educational Building Child Care Center.

All of the facts are stipulated and found accordingly. The pertinent facts are summarized below.

Dorothy E. Warner (petitioner) was a legal resident of Milford, Ohio, when her petition was…

2Cases cited6 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  3. United States v. CorrellSupreme Court of the United States · 1967
  4. Helvering v. WinmillSupreme Court of the United States · 1938
  5. Commissioner v. Estate of NoelSupreme Court of the United States · 1965

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

3Cited by9 opinions

  1. Perry v. CommissionerUnited States Tax Court · 1989
  2. Poinier v. CommissionerUnited States Tax Court · 1988
  3. Zoltan v. CommissionerUnited States Tax Court · 1982
  4. Herder v. CommissionerUnited States Tax Court · 1979
  5. Nyhus v. CommissionerUnited States Tax Court · 1979

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

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