Legal Opinion

Hughes v. Commissioner

United States Tax Court

Decided December 16, 1975No. Docket No. 1170-74Published

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

William Hughes and Mary Ann Hughes, Petitioners v. Commissioner of Internal Revenue, Respondent

Hughes v. Commissioner

Docket No. 1170-74

United States Tax Court

65 T.C. 566; 1975 U.S. Tax Ct. LEXIS 12;

December 16, 1975, Filed

Decision will be entered under Rule 155.

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…

Also in this document: Dissent · Dawson; Dissent · Fay.

2Cases cited14 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Primuth v. CommissionerUnited States Tax Court · 1970
  3. Jones v. CommissionerUnited States Tax Court · 1970
  4. Commissioner of Internal Revenue v. Walter H. Mendel and Lillian Mendel, Walter H. Mendel and Lillian Mendel v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1965
  5. Mendel v. CommissionerUnited States Tax Court · 1963

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