Brewin v. Commissioner
United States Tax Court
Venue for appeal of Tax Court cases lies in the judicial district in which the taxpayer resides. Sec. 7482, I.R.C. 1954. Held, for purposes of sec. 7482 the term residence means domicile. Held, further, expenditures incurred while taxpayer is on home leave are not deductible under sec. 162.
1Opinion of the Court
Sterrett, Judge:
Respondent, on January 30, 1974, issued a statutory notice in which he determined a deficiency in petitioners’ Federal income tax paid for calendar year 1971 in the amount of $393.64. The issue presented for our determination is the deductibility of expenses incurred while petitioner-husband was on home leave. However, in order to determine this issue we must first decide in which circuit appeal would lie.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts, and the exhibits attached thereto, are incorporated herein by this…
2Cases cited8 opinions
- TEXAS v. FLORIDA Et Al.Supreme Court of the United States · 1939
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