Warren v. Commissioner
United States Tax Court
1. Petitioner was continuously employed during the taxable year 1944 at the Navy Yard in Charleston, South Carolina, and lived there during that time. He found no housing accommodations for his wife and two children in Charleston and maintained a residence for them 300 miles from Charleston at Cornelia, Georgia, where he had lived prior to his employment at the Navy Yard.
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1. Petitioner was continuously employed during the taxable year 1944 at the Navy Yard in Charleston, South Carolina, and lived there during that time. He found no housing accommodations for his wife and two children in Charleston and maintained a residence for them 300 miles from Charleston at Cornelia, Georgia, where he had lived prior to his employment at the Navy Yard. Petitioner's expenditures for meals and lodging in Charleston and for transportation between Charleston and Cornelia on week end visits, held, nondeductible because not incurred in pursuit of his employer's business.…
1Opinion of the Court
OPINION*
Harlan, Judge:
Petitioner contends that the cost of his meals and lodging while he was employed in Charleston, South Carolina, and the cost of his transportation to and from Cornelia, Georgia, where he maintained a residence for his wife and children, are deductible under section 23 (a) (1) (A), Internal Revenue Code, as travel expenses incurred while away from home in pursuit of a trade'or business. Respondent determined that these expenditures were “personal, living or family expenses” within the meaning of section 24 (a) (1), Internal Revenue Code, and hence not deductible.
The…
2Cases cited5 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Schurer v. CommissionerUnited States Tax Court · 1944
- O'Hara v. CommissionerUnited States Tax Court · 1946
- Johnson v. CommissionerUnited States Tax Court · 1947
- Carranza v. CommissionerUnited States Tax Court · 1948
3Cited by55 opinions
- Peurifoy v. CommissionerSupreme Court of the United States · 1958
- Commissioner of Internal Revenue v. James E. Peurifoy, Paul v. Stines and Betty O. Stines, John S. Hall and Doris D. HallCourt of Appeals for the Fourth Circuit · 1958
- Harvey v. CommissionerUnited States Tax Court · 1959
- Verner v. Comm'rUnited States Tax Court · 1963
- Courtney v. CommissionerUnited States Tax Court · 1959
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