Legal Opinion

Walker v. Commissioner

United States Tax Court

Decided December 13, 1993No. Docket No. 20919-91Published

P, a logger, drove daily from his residence to numerous job sites located throughout the Black Hills National Forest. P worked approximately 6 to 7 hours per day cutting trees. He also worked 7 hours per week at his residence on tool repairs and maintenance. P stored his equipment and supplies and took calls for jobs at his residence as well.

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P, a logger, drove daily from his residence to numerous job sites located throughout the Black Hills National Forest. P worked approximately 6 to 7 hours per day cutting trees. He also worked 7 hours per week at his residence on tool repairs and maintenance. P stored his equipment and supplies and took calls for jobs at his residence as well. R allowed 60 percent of P's vehicle-related expenses, which represented expenses for driving between job sites during the day and for trips to obtain supplies and repairs. R disallowed the remaining 40 percent of P's vehicle-related expenses, which…

1Opinion of the Court

Charles W. and Cathe R. Walker, Petitioners v. Commissioner of Internal Revenue, Respondent

Walker v. Commissioner

Docket No. 20919-91

United States Tax Court

101 T.C. 537; 1993 U.S. Tax Ct. LEXIS 77; 101 T.C. No. 36;

December 13, 1993, Filed

Walker v. Commissioner, T.C. Memo 1993-311, 1993 Tax Ct. Memo LEXIS 313 (T.C., 1993)

Decision will be entered under Rule 155.

P, a logger, drove daily from his residence to numerous job sites located throughout the Black Hills National Forest. P worked approximately 6 to 7 hours per day cutting trees. He also worked 7 hours per week at his residence on tool…

2Cases cited29 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Commissioner v. FlowersSupreme Court of the United States · 1946
  3. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  4. United States v. SilkSupreme Court of the United States · 1947
  5. Sanford v. CommissionerUnited States Tax Court · 1968

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