Legal Opinion

F. M. Williams v. George D. Patterson, District Director of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided January 12, 1961No. 18371_1PublishedCited by 31 opinions

1Opinion of the Court

WISDOM, Circuit Judge.

The controversy between the taxpayer and the District Director of Internal Revenue is over the disallowance of a railroad conductor’s income tax deduction of expenditures for lodging, meals, and tips as “traveling .expenses” during six-hour layovers “away from home” on regular trips, each trip requiring an absence from his home terminal of about sixteen hours. Similar controversies have been the subject of decisions by the Tax Court but, as far as we know, the instant case is one of first impression in the federal courts.

F. M. Williams is a railroad conductor with more…

2Cases cited8 opinions

  1. Commissioner v. FlowersSupreme Court of the United States · 1946
  2. Peurifoy v. CommissionerSupreme Court of the United States · 1958
  3. Charles Crowther and Ivy L. Crowther v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
  4. Osteen v. CommissionerUnited States Tax Court · 1950
  5. Waters v. CommissionerUnited States Tax Court · 1949

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

3Cited by31 opinions

  1. William W. Steinhort and Mildred Steinhort v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
  2. George Harvey James v. United StatesCourt of Appeals for the Ninth Circuit · 1962
  3. Mortrud v. CommissionerUnited States Tax Court · 1965
  4. Allan L. Hanson and Florence S. Hanson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
  5. Commissioner of Internal Revenue v. William A. BagleyCourt of Appeals for the First Circuit · 1967

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

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