Curphey v. Commissioner
United States Tax Court
Petitioner, a dermatologist employed by a hospital, also owned and managed six rental properties. Held, his rental activities constituted a business for the purpose of sec. 280A, I.R.C. 1954. Held, further, petitioner was entitled to deduct expenses incurred for the use of a room in his residence, exclusively and on a regular basis, as an office in connection with his rental business, where such home office was the principal place at which he carried on that business.
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Petitioner, a dermatologist employed by a hospital, also owned and managed six rental properties. Held, his rental activities constituted a business for the purpose of sec. 280A, I.R.C. 1954. Held, further, petitioner was entitled to deduct expenses incurred for the use of a room in his residence, exclusively and on a regular basis, as an office in connection with his rental business, where such home office was the principal place at which he carried on that business. Sec. 280A(c)(1)(A), I.R.C. 1954. Held, further, costs of local transportation between such office in residence and…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined a deficiency of $189 in petitioner’s Federal income tax for the year 1976. Concessions having been made, the issues remaining for decision are whether petitioner is entitled to a deduction in connection with an office in his home under section 280A1 and a deduction for automobile expenses incurred in travel between his home and certain rental properties which he owned and managed.
FINDINGS OF FACT
Some of the facts were stipulated. The stipulation of facts and the attached exhibit are incorporated herein by this reference.
Petitioner was a resident of…
2Cases cited36 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Higgins v. CommissionerSupreme Court of the United States · 1941
- United States v. GilmoreSupreme Court of the United States · 1963
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
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3Cited by111 opinions
- Jackson v. CommissionerUnited States Tax Court · 1986
- Hynes v. CommissionerUnited States Tax Court · 1980
- Baie v. CommissionerUnited States Tax Court · 1980
- Jackson v. CommissionerUnited States Tax Court · 1981
- Stanley D. Pomarantz and Linda Burnett Pomarantz v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
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