Chimento v. Commissioner
United States Tax Court
T was a writer of technical reports and manuals who obtained employment with various firms that in turn had contracts or arrangements with various corporations to furnish writers to such corporations to prepare reports and manuals for them. From May 1956 when T left the Air Force until September 1963, he held 13 different jobs at widely scattered locations in California, Texas, Colorado, Massachusetts, New York, and Pennsylvania.
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T was a writer of technical reports and manuals who obtained employment with various firms that in turn had contracts or arrangements with various corporations to furnish writers to such corporations to prepare reports and manuals for them. From May 1956 when T left the Air Force until September 1963, he held 13 different jobs at widely scattered locations in California, Texas, Colorado, Massachusetts, New York, and Pennsylvania. In between jobs, T often stayed at his brother's house in Garfield, N.J., where he kept certain belongings during his jobs; he paid no rent to his brother. In…
1Opinion of the Court
OPINION
Raum, Judge:
Section 162(a), I.B.C. 1954, provides for the deduction of ordinary and necessary business expenses, which include “traveling expenses (including amounts expended for meals and lodging other than amounts which are lavish or extravagant under the circumstances) while away from home in the pursuit of a trade or business.” The dispute in this case concerns whether petitioner was “away from home” during 1965. Petitioner claims his home was his brother’s house in Garfield, N.J., while the Commissioner contends that it was in Binghamton, N.Y. We sustain the Commissioner.
Cases…
2Cases cited20 opinions
- Peurifoy v. CommissionerSupreme Court of the United States · 1958
- Kroll v. CommissionerUnited States Tax Court · 1968
- Commissioner v. StidgerSupreme Court of the United States · 1967
- Garlock v. CommissionerUnited States Tax Court · 1960
- William W. Steinhort and Mildred Steinhort v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
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3Cited by1 opinion
- Chimento v. CommissionerUnited States Tax Court · 1969