Legal Opinion

Sullivan v. Commissioner

United States Board of Tax Appeals

Decided November 26, 1924No. Docket No. 249PublishedCited by 61 opinions

The cost of transportation paid by an individual living at a distance from his place of business, in going to and returning from such place of business, is not deductible as a business expense. The operating cost, including depreciation, of an automobile so used by an individual is not deductible as a business expense.

1Opinion of the Court

*94OPINION.

Korner:

The only question involved in this appeal is whether an individual who. lives at a distance from his place of business may deduct as á business expense the cost of his transportation from his home to his office and return. Section 214 of the Revenue Acts of 1918 and 1921 provides, in part :

Sec. 214. (a) In computing net income there shall be allowed as deductions:(1) All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business. * * *(8) A reasonable allowance for the exhaustion, wear and tear of property used in the trade…

2Cited by61 opinions

  1. Kroll v. CommissionerUnited States Tax Court · 1968
  2. Heuer v. CommissionerUnited States Tax Court · 1959
  3. Verner v. Comm'rUnited States Tax Court · 1963
  4. Courtney v. CommissionerUnited States Tax Court · 1959
  5. Zimmerman v. CommissionerUnited States Tax Court · 1978

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