Galyen v. Comm'r
United States Tax Court
The Telecommunication Relay Service (TRS) enables a hearing- impaired individual to communicate with a hearing individual over the telephone through the use of a relay operator. Ps subscribed to the AdaCom program which provided an alternative to the TRS through the use of a computer rather than a relay operator. On their 2000, 2001, and 2002 Federal income tax returns, Ps claimed a disabled access credit. See sec. 44, I.R.C.
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The Telecommunication Relay Service (TRS) enables a hearing- impaired individual to communicate with a hearing individual over the telephone through the use of a relay operator. Ps subscribed to the AdaCom program which provided an alternative to the TRS through the use of a computer rather than a relay operator. On their 2000, 2001, and 2002 Federal income tax returns, Ps claimed a disabled access credit. See sec. 44, I.R.C. Ps also claimed a sec. 162, I.R.C., trade or business expense deduction. R disallowed the credit and deduction. Held: Because the AdaCom program was not acquired by Ps…
1Opinion of the Court
RALPH E. AND MILDRED E. GALYEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Galyen v. Comm'r
No. 5092-04
United States Tax Court
T.C. Memo 2006-30; 2006 Tax Ct. Memo LEXIS 30; 91 T.C.M. (CCH) 762;
February 22, 2006, Filed
The Telecommunication Relay Service (TRS) enables a hearing-
impaired individual to communicate with a hearing individual
over the telephone through the use of a relay operator. Ps
subscribed to the AdaCom program which provided an alternative
to the TRS through the use of a computer rather than a relay
operator. On their 2000, 2001, and 2002 Federal income tax
returns,…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
4 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Arevalo v. CommissionerCourt of Appeals for the Fifth Circuit · 2006