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Commissioner v. Flowers
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Commissioner v. Flowers : ウィキペディア英語版
Commissioner v. Flowers

''Commissioner v. Flowers'', , was a Federal income tax case before the Supreme Court of the United States. The Court held that in order to deduct the expense of traveling under §162, the expense must be incurred while away from home, and must be a reasonable expense necessary or appropriate to the development and pursuit of a trade or business. In this case, the attorney in question could only deduct traveling expenses from her gross income when the railroad's business forced attorney to travel and live temporarily at some place other than the railroad's principal place of business. Where attorney preferred for personal reasons to live in a different state from the location of his employer's principal office, and his duties required frequent trips to that office, the evidence sustained Tax Court's finding that the necessary relation between expenses of such trips and the railroad's business was lacking.
==Background==
The taxpayer lived and practiced law in Jackson, Mississippi for a railroad.〔326 U.S. 465 (1946)〕 The railroad’s home offices were in Mobile, Alabama.〔''Id.''〕 The taxpayer was offered a job in Mobile (185 miles from Jackson), but was unwilling to move from Jackson.〔''Id.''〕 The taxpayer arranged, with the railroad, to stay in Jackson on the condition that he pay his own traveling expenses between Mobile and Jackson and his own living expenses in both places.〔''Id.''〕 The taxpayer deducted the amounts incurred to travel between Jackson and Mobile as traveling expenses under §162(a)(2) of the Internal Revenue Code.〔''Id. at 469.''〕

抄文引用元・出典: フリー百科事典『 ウィキペディア(Wikipedia)
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