Pollei v. Commissioner
United States Tax Court
Ps are police captains who receive a car allowance to operate specially equipped, personally owned vehicles in the performance as employees. Ps have deducted expenses of operation "against" the allowance. R has only questioned the portion of the deductions which are attributable to travel between police headquarters and Ps' homes.
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Ps are police captains who receive a car allowance to operate specially equipped, personally owned vehicles in the performance as employees. Ps have deducted expenses of operation "against" the allowance. R has only questioned the portion of the deductions which are attributable to travel between police headquarters and Ps' homes. Ps have attempted to distinquish their case from others where we have found travel to be commuting by pointing out the requirement to be in contact with headquarters by radios. R contends that Ps must be in radio contact during any use of the specially equipped…
1Opinion of the Court
Jon R. Pollei and Carol J. Pollei, Petitioners v. Commissioner of Internal Revenue, Respondent; Harry W. Patrick and Renee L. Patrick, Petitioners v. Commissioner of Internal Revenue, Respondent
Pollei v. Commissioner
Docket Nos. 28737-84, 28738-84
United States Tax Court
87 T.C. 869; 1986 U.S. Tax Ct. LEXIS 31; 87 T.C. No. 56;
October 28, 1986, Filed
Decisions will be entered for the respondent.
Ps are police captains who receive a car allowance to operate specially equipped, personally owned vehicles in the performance as employees. Ps have deducted expenses of operation "against" the allowance. R…
2Cases cited15 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Fausner v. CommissionerSupreme Court of the United States · 1973
- United States v. Lee W. Tauferner and Carolyn E. TaufernerCourt of Appeals for the Tenth Circuit · 1969
- Fausner v. CommissionerUnited States Tax Court · 1971
- Gilberg v. CommissionerUnited States Tax Court · 1971
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