Boser v. Commissioner
United States Tax Court
H was employed as a second officer with UAL. H purchased an aircraft, which he used to commute to work and to make other personal trips, but the operation of such aircraft did also improve his employment skills as a second officer. Held, H is allowed to deduct the expenses of operating an aircraft to the extent that such operations were needed to maintain his employment skills, but the remaining expenses are personal and not deductible.
1Opinion of the Court
Simpson, Judge:
The Commissioner determined a deficiency of $1,106 in the petitioners’ Federal income tax for 1976. The sole issue for decision is whether expenses incurred by the petitioners in the operation of a private aircraft are deductible educational expenses.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioners, Robert J. and Phyllis P. Boser, husband and wife, maintained their legal residence in Redding, Calif., at the time they filed their petition in this case. They timely filed their joint Federal income tax return for 1976 with the…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Kornhauser v. United StatesSupreme Court of the United States · 1928
16 more not listed; retrieve them via the Exa API.
3Cited by61 opinions
- Heineman v. CommissionerUnited States Tax Court · 1984
- Noyce v. CommissionerUnited States Tax Court · 1991
- Walker v. CommissionerUnited States Tax Court · 1993
- Brizell v. CommissionerUnited States Tax Court · 1989
- Herman v. CommissionerUnited States Tax Court · 1985
56 more not listed; retrieve them via the Exa API.