Legal Opinion

Freeman v. Comm'r

United States Tax Court

Decided September 16, 2009No. Nos. 12761-08, 12793-08Unpublished

In 1999 and 2000 P worked as a courier for an auto parts delivery business. Each workday, P drove his own vehicle from a warehouse to several customers in a loop through Maryland and Delaware, dropping off auto parts and picking up cash and returned auto parts to deliver back to the warehouse.

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In 1999 and 2000 P worked as a courier for an auto parts delivery business. Each workday, P drove his own vehicle from a warehouse to several customers in a loop through Maryland and Delaware, dropping off auto parts and picking up cash and returned auto parts to deliver back to the warehouse. P drove from the location of his last customer to his home in the evening and then drove from his home to the warehouse in the morning to deliver the cash and returned auto parts he had collected the previous day. At trial P alleged for the first time that his wife also worked as a courier for the auto…

1Opinion of the Court

LESLIE FREEMAN, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Freeman v. Comm'r

Nos. 12761-08, 12793-08

United States Tax Court

T.C. Memo 2009-213; 2009 Tax Ct. Memo LEXIS 216; 98 T.C.M. (CCH) 57939;

September 16, 2009, Filed

In 1999 and 2000 P worked as a courier for an auto parts delivery business. Each workday, P drove his own vehicle from a warehouse to several customers in a loop through Maryland and Delaware, dropping off auto parts and picking up cash and returned auto parts to deliver back to the warehouse. P drove from the location of his last customer to his home in the…

2Cases cited14 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  3. Commissioner v. FlowersSupreme Court of the United States · 1946
  4. Tucker v. CommissionerUnited States Tax Court · 1971
  5. Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938

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