Sheldon v. Commissioner
United States Tax Court
Held: That petitioner, a physician employed as a full-time anesthesiologist at a county hospital, is not entitled to deduct as a business expense the cost of operating her automobile in traveling from her home to the hospital in order to assist in specially scheduled operations and emergency cases. The amounts claimed constituted personal commuting expenses which are nondeductible under sec. 262, I.R.C. 1954.
1Opinion of the Court
Dawson, Judge:
Respondent determined the following income tax deficiencies against petitioner:
Tear Deficiency
1962 _$456. 01
1963 _ 480.17
1964 _ 518.94
Petitioner alleged no error in her petition with respect to respondent’s disallowance of certain deductions claimed for the cost of accident and health insurance and the issue was not raised at trial. It is therefore treated as abandoned. Petitioner has conceded that 40 percent of the automobile expenses deducted during the years 1962 through 1964 were incurred for personal reasons. Consequently, the only issue remaining for decision is whether,…
2Cases cited4 opinions
- Heuer v. CommissionerUnited States Tax Court · 1959
- Sapp v. CommissionerUnited States Tax Court · 1961
- Clarence J. Sapp and Hilda C. Sapp v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- Marot v. CommissionerUnited States Tax Court · 1961
3Cited by24 opinions
- O'Hare v. CommissionerUnited States Tax Court · 1970
- MANNING v. COMMISSIONERUnited States Tax Court · 1993
- C. A. White Trucking Co. v. CommissionerUnited States Tax Court · 1977
- Dietrich v. CommissionerUnited States Tax Court · 1971
- Squires v. United StatesDistrict Court, C.D. California · 1968
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