Legal Opinion

Patterson v. Commissioner

United States Tax Court

Decided September 10, 1979No. Docket Nos. 164-78, 165-78UnpublishedCited by 4 opinions

Petitioner was a public school teacher and administrator. On his returns for 1974 and 1975, petitioner claimed "business" deductions for the total amount shown on 132 and 97 pages, respectively, of cash register tapes, receipts, bills, cashier checks, and similar documents, photocopies of which were attached to the returns.

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Petitioner was a public school teacher and administrator. On his returns for 1974 and 1975, petitioner claimed "business" deductions for the total amount shown on 132 and 97 pages, respectively, of cash register tapes, receipts, bills, cashier checks, and similar documents, photocopies of which were attached to the returns. Held: Petitioner failed to prove error in respondent's determination that the claimed deductions are not allowable as trade or business expenses; certain amounts allowed under sections 164 and 212(3), I.R.C. 1954. Held further: Petitioner failed to prove error in…

1Opinion of the Court

SAMUEL F. PATTERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Patterson v. Commissioner

Docket Nos. 164-78, 165-78.

United States Tax Court

T.C. Memo 1979-362; 1979 Tax Ct. Memo LEXIS 162; 39 T.C.M. (CCH) 82; T.C.M. (RIA) 79362;

September 10, 1979, Filed

Petitioner was a public school teacher and administrator. On his returns for 1974 and 1975, petitioner claimed "business" deductions for the total amount shown on 132 and 97 pages, respectively, of cash register tapes, receipts, bills, cashier checks, and similar documents, photocopies of which were attached to the returns.

Held:…

2Cases cited18 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Commissioner v. HeiningerSupreme Court of the United States · 1943
  4. Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
  5. Collector v. DaySupreme Court of the United States · 1871

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

3Cited by4 opinions

  1. Akey v. Comm'rUnited States Tax Court · 2014
  2. McGovern v. Comm'rUnited States Tax Court · 2013
  3. Morgain Mary McGovern v. CommissionerUnited States Tax Court · 2013
  4. Terry Gene Akey v. CommissionerUnited States Tax Court · 2014

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