Sullivan v. Commissioner
United States Tax Court
Petitioner, a construction worker, used his car to transport himself and his 32-pound bag of tools from his home to various job locations where his employer was constructing buildings. He also brought his tools home with him because of the danger they might be stolen and because he might be assigned to a different job location the next day. Held, the amounts paid for such transportation were personal expenses and not deductible as business expenses.
1Opinion of the Court
Mutjronev, Judge:
Respondent determined a deficiency in petitioner’s 1962 income tax in the amount of $540.10. The issue that is left after certain concessions is whether petitioner, a construction worker, is entitled to deduct travel expenses in traveling in his automobile between his home and various jobsites in New York.
FINDINGS OF FACT
Some of the facts have been stipulated and they are found accordingly.
Upon his income tax return for 1962, which petitioner filed with the district director of internal revenue, Manhattan, New York, he took deduction for a total of $1,494.72 for…
2Cases cited7 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Heuer v. CommissionerUnited States Tax Court · 1959
- Charles Crowther and Ivy L. Crowther v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Bruton v. CommissionerUnited States Tax Court · 1947
2 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Fausner v. CommissionerUnited States Tax Court · 1971
- Gilberg v. CommissionerUnited States Tax Court · 1971
- Lawrence D. Sullivan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- John J. Tyne, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1967
- Hitt v. CommissionerUnited States Tax Court · 1971
18 more not listed; retrieve them via the Exa API.