Smith v. Commissioner
United States Tax Court
Petitioner Ray Smith was employed from May 1952 to June 1954 as an electrician by five different contractors who, during such time, had contracts for electrical work to be performed in the construction of a plant which the Aluminum Company of America was building near Rockdale, Texas. Each contractor for whom petitioner worked during this time was separate and independent of the other and petitioner worked for only one contractor at a time.
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Petitioner Ray Smith was employed from May 1952 to June 1954 as an electrician by five different contractors who, during such time, had contracts for electrical work to be performed in the construction of a plant which the Aluminum Company of America was building near Rockdale, Texas. Each contractor for whom petitioner worked during this time was separate and independent of the other and petitioner worked for only one contractor at a time. Petitioner was continuously thus employed at Rockdale during the entire year 1953 and was not employed elsewhere. At all times that petitioner was…
1Opinion of the Court
OPINION.
Black, Judge:
Petitioner contests the disallowance of $1,657.50 expended for meals and lodging in Eockdale during 1953, and of $458.64 expended in the same year in making trips from Eockdale to Austin to spend the weekends with his wife. The grounds which petitioner urges against the action of the Commissioner in making these disallowances is that the employment of petitioner at Eockdale during 1953 was temporary in character and that the amounts in question are deductible as traveling expenses under either section 22(n) (2) or section 23(a) (1) (A), I.R.C. 1939.
The Commissioner, in…
2Cases cited1 opinion
- Eaves v. CommissionerUnited States Tax Court · 1960
3Cited by16 opinions
- Norwood v. CommissionerUnited States Tax Court · 1976
- Blatnick v. CommissionerUnited States Tax Court · 1971
- Sapson v. Comm'rUnited States Tax Court · 1968
- Muhl v. CommissionerUnited States Tax Court · 1986
- Le Towt v. CommissionerUnited States Tax Court · 1963
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