Legal Opinion

Muhl v. Commissioner

United States Tax Court

Decided July 24, 1986No. Docket No. 3580-84UnpublishedCited by 2 opinions

During 1979 and 1980, P operated a farm near Waco, Tex., and spent the weekends there. During the week, he worked as an electrician near Houston, Tex., and derived his principal income from that work. Held: (1) P's employment in the Houston area was temporary until July 1980 so that his travel expenses incurred before that time are deductible, but thereafter, his employment became indefinite.

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During 1979 and 1980, P operated a farm near Waco, Tex., and spent the weekends there. During the week, he worked as an electrician near Houston, Tex., and derived his principal income from that work. Held: (1) P's employment in the Houston area was temporary until July 1980 so that his travel expenses incurred before that time are deductible, but thereafter, his employment became indefinite. (2) P's transportation expenses between the Houston area and Waco are deductible as ordinary and necessary business expenses since P had a place of business in each area.

1Opinion of the Court

JAMES F. MUHL and BOBBIE L. MUHL, Petitioners v. COMMISSIONER OF INTERNAL, Respondent

Muhl v. Commissioner

Docket No. 3580-84.

United States Tax Court

T.C. Memo 1986-309; 1986 Tax Ct. Memo LEXIS 296; 51 T.C.M. (CCH) 1538; T.C.M. (RIA) 86309;

July 24, 1986.

During 1979 and 1980, P operated a farm near Waco, Tex., and spent the weekends there. During the week, he worked as an electrician near Houston, Tex., and derived his principal income from that work. Held: (1) P's employment in the Houston area was temporary until July 1980 so that his travel expenses incurred before that time are deductible,…

2Cases cited20 opinions

  1. Commissioner v. FlowersSupreme Court of the United States · 1946
  2. Peurifoy v. CommissionerSupreme Court of the United States · 1958
  3. Kroll v. CommissionerUnited States Tax Court · 1968
  4. Tucker v. CommissionerUnited States Tax Court · 1971
  5. 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

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

3Cited by2 opinions

  1. HeapeUnited States Tax Court · 1992
  2. Wilson v. CommissionerUnited States Tax Court · 1989

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