Opinion

Noyce v. Commissioner

  • 97 T.C. 670
  • 97 T.C. No. 46
  • 1991 U.S. Tax Ct. LEXIS 108
Court
United States Tax Court
Filed
Dec 16, 1991
Status
Published
Author
Parr
On the bench
RUWE,NIMS,CHABOT,KORNER,SWIFT,GERBER,WRIGHT,WELLS,WHALEN,COLVIN,BEGHE
Cited by
28 cases
Authority
More cited than 10.5%

concluding that the taxpayer personally incurred airplane expenses pursuant to Intel's written travel reimbursement policy requiring its officers to incur certain expenses for Intel's benefit without reimbursement

How later courts described this case

  • concluding that the taxpayer personally incurred airplane expenses pursuant to Intel's written travel reimbursement policy requiring its officers to incur certain expenses for Intel's benefit without reimbursement
  • distinguishing sec. 168, the authority for deducting an allowance for depreciation in that case, from sec. 162↩
  • taxpayer allowed to deduct depreciation under section 168 on an airplane that appreciated in economic value by 27 percent from the date of purchase until the time of trial
  • taxpayer allowed to deduct depreciation under § 168 on an airplane that appreci ated in economic value by 27 percent from the date of purchase to the time of trial

Written by the judges who cited it.

The opinion

PARR, J, dissenting: In addition to the reasons set forth in the dissent of Judge Jacobs, with which I agree, I would also find that use of petitioner’s private plane “did not arise directly out of the exigencies of the business of the corporation.” Noland v. Commissioner, 269 F.2d 108, 113 (4th Cir. 1959), affg. a Memorandum Opinion of this Court.

Parker, J., agrees with this dissent.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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