MORTON FRANK V. COMMISSIONER
20 T.C. 511 (1953)
NATURE OF THE CASE: This was a dispute over travel expenses.
FACTS: Frank (P) took a trip to investigate the possibility of acquiring a newspaper or
radio station. P took his wife and went from Pittsburgh as far as San Diego. On the way they
interviewed people. Eventually they took employment with the Arizona Times and remained in
that city for the first half of 1946. While working in Phoenix they made several trips to
locate a purchase candidate. They traveled all over the U.S. in this pursuit. Offers of
purchase were made to several owners. Estimated travel expenses incurred were almost $5,925.
They took these expenses as a deduction but none were claimed to be incurred in connection
with their employment with the Arizona Times. Eventually by November 1946 the bought a
newspaper in Canton, Ohio. The IRS did not like this deduction and disallowed it. P filed
with the tax court.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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