Legal Opinion
Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
United States Tax Court
Decided August 9, 2004No. 1188-01Unknown
1Opinion of the Court
123 T.C. No. 9
UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1188-01. Filed August 9, 2004. P’s wholly owned subsidiary S made payments to certain truck drivers whom S leased to certain trucking companies. S intended such payments to cover food and beverages expenses that such truck drivers paid while traveling away from home. Held, the parties’ respective positions as to the import of Beech Trucking Co. v. Commissioner,
118 T.C. 428
(2002), rejected. Held, further, on the facts presented, S is…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Hampshire v. MaineSupreme Court of the United States · 2001
- Nationwide Mutual Insurance v. DardenSupreme Court of the United States · 1992
- Tokarski v. CommissionerUnited States Tax Court · 1986
- Gladys T. Geiger v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
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