Sapson v. Comm'r
United States Tax Court
Since petitioner kept a permanent room in San Antonio, Tex., at a rental cost to him of approximately $ 600 a year, considered San Antonio as his headquarters, worked for an employer with its offices in San Antonio, and received per diem only when away from San Antonio, he had his home in San Antonio within the meaning of sec. 162(a)(2), I.R.C. 1954, and is entitled to deduct his traveling expenses when away from San Antonio in pursuit of his business.
1Opinion of the Court
OPINION
Petitioner’s contention appears to be that San Antonio was, during the years here in issue and had been for many years prior thereto, his principal place of business or post of duty, and that for that reason it was his “home” within the meaning of section 162(a) (2). Petitioner, from his statements at the trial, apparently had the understanding that respondent took the position that regardless of the fact that he had a principal place of employment or post of duty in San Antonio, he would not be entitled to deduct traveling expenses while away from San Antonio unless he was able to…
2Cases cited14 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- United States v. CorrellSupreme Court of the United States · 1967
- Garlock v. CommissionerUnited States Tax Court · 1960
- Schurer v. CommissionerUnited States Tax Court · 1944
- George Harvey James v. United StatesCourt of Appeals for the Ninth Circuit · 1962
9 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Michaels v. CommissionerUnited States Tax Court · 1969
- Bochner v. CommissionerUnited States Tax Court · 1977
- Rambo v. CommissionerUnited States Tax Court · 1978
- Barone v. CommissionerUnited States Tax Court · 1985
- Dean v. CommissionerUnited States Tax Court · 1970
17 more not listed; retrieve them via the Exa API.