Moorman v. Commissioner
United States Tax Court
1. Gross Income -- Commissions. -- Gross income includes entire amounts received by the petitioner as commissions on sales of securities, rather than only the difference between such amounts and the amounts of the expense accounts submitted by the petitioner to his employer. 2. Deductions -- Adjusted Gross Income. -- Expenses of travel, meals, and lodging while away from home, held deductible in determining adjusted gross income under section 22 (n) (2) of the Internal…
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1. Gross Income -- Commissions. -- Gross income includes entire amounts received by the petitioner as commissions on sales of securities, rather than only the difference between such amounts and the amounts of the expense accounts submitted by the petitioner to his employer. 2. Deductions -- Adjusted Gross Income. -- Expenses of travel, meals, and lodging while away from home, held deductible in determining adjusted gross income under section 22 (n) (2) of the Internal Revenue Code of 1939. The amounts of such deductible expenses found. Other expenses held not deductible under section 22 (n)…
1Opinion of the Court
OPINION.
Atkins, Judge:
The petitioner included in his returns as gross income from commissions only the difference between the amounts actually paid to him by his employer and the amounts shown in the expense accounts which he submitted to his employer. The respondent has determined that the full amount of commissions earned (with some adjustments for 1950 and 1951 on account of a $2,000 reserve) constitutes gross income and computed net income by deducting therefrom the amounts which he determined to be allowable expenses. In view of this determination he further determined that it would be…
2Cases cited1 opinion
- Old Mission Portland Cement Co. v. HelveringSupreme Court of the United States · 1934
3Cited by42 opinions
- Patin v. CommissionerUnited States Tax Court · 1987
- Woodbury v. CommissionerUnited States Tax Court · 1967
- Alabama-Georgia Syrup Co. v. CommissionerUnited States Tax Court · 1961
- Duncan v. CommissionerUnited States Tax Court · 1958
- United States v. Roy O. Disney and Edna F. DisneyCourt of Appeals for the Ninth Circuit · 1969
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