Hughes v. Commissioner
United States Tax Court
Petitioner was transferred to Spain by his employer, who reimbursed him for expenses incurred in the move. Respondent concedes that petitioner satisfies all the requirements for a moving expense deduction under sec. 217, I.R.C. 1954, but contends that the portion of such expenses allocable to tax-exempt income earned subsequent to the move cannot be deducted.
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Petitioner was transferred to Spain by his employer, who reimbursed him for expenses incurred in the move. Respondent concedes that petitioner satisfies all the requirements for a moving expense deduction under sec. 217, I.R.C. 1954, but contends that the portion of such expenses allocable to tax-exempt income earned subsequent to the move cannot be deducted. Held: Petitioner is not entitled to deduct fully his moving expenses incurred under sec. 217. Such expenses are partially allocable to or chargeable against exempt earned income and consequently partially disallowed by sec. 911(a). Jon…
1Opinion of the Court
OPINION
Sterrett, Judge:
The respondent determined a deficiency in petitioners’ Federal income tax for the taxable year 1971 in the amount of $727.94.
The principal issue presented for our decision is whether section 911(a)1 precludes petitioners from deducting part of their moving expenses, which otherwise satisfy the requirements of section 217. If we conclude that a portion of the moving expenses is not deductible because it is allocable to income exempt from Federal income tax, then we must decide (1) whether the reimbursement of petitioners’ relocation expenses, received in 1971,…
2Cases cited6 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Primuth v. CommissionerUnited States Tax Court · 1970
- Jones v. CommissionerUnited States Tax Court · 1970
- Hartung v. CommissionerUnited States Tax Court · 1970
- Hartung v. CommissionerCourt of Appeals for the Ninth Circuit · 1973
1 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Redding v. CommissionerUnited States Tax Court · 1979
- Bush Bros. & Co. v. CommissionerUnited States Tax Court · 1979
- Butka v. CommissionerUnited States Tax Court · 1988
- Roque v. CommissionerUnited States Tax Court · 1976
- Christensen v. CommissionerUnited States Tax Court · 1978
14 more not listed; retrieve them via the Exa API.