Sapp v. Commissioner
United States Tax Court
Held, a medical doctor may not depreciate the entire cost or operating expenses of a business automobile solely because he was constantly on emergency call while using said automobile where some of such use was for activities personal in nature.
1Opinion of the Court
Forrester, Judge:
Respondent has determined deficiencies in petitioners’ income tax as follows:
Year Defielency
1955 _$409.80
1956 _ 749.81
1957 _ 892.38
The only issue not fully resolved by the stipulation filed herein is the extent to which depreciation and expenses are allowable with respect to a certain automobile.
FINDINGS OF FACT.
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife residing in Rome, Georgia, who filed joint Federal income tax returns for the calendar years 1955, 1956, and 1957 with the district director of internal revenue at Atlanta,…
2Cases cited3 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Heuer v. CommissionerUnited States Tax Court · 1959
- Marot v. CommissionerUnited States Tax Court · 1961
3Cited by47 opinions
- William W. Steinhort and Mildred Steinhort v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- International Artists, Ltd. v. CommissionerUnited States Tax Court · 1970
- Turner v. CommissionerUnited States Tax Court · 1971
- Clarence J. Sapp and Hilda C. Sapp v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- Sheldon v. CommissionerUnited States Tax Court · 1968
42 more not listed; retrieve them via the Exa API.