Clarence J. Sapp and Hilda C. Sapp v. Commissioner of Internal Revenue
This text of 309 F.2d 143 (Clarence J. Sapp and Hilda C. Sapp v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
This petition for review raises the question whether the Tax Court decision was clearly erroneous in finding that a portion of the automobile expense, including an allowance for -depreciation, claimed by the taxpayer as a deduction, was personal in nature and not deductible, where, in addition to using it in his medical practice, the taxpayer used the automobile to “commute” to work, to go home for lunch, and to attend social functions.
The facts are adequately set forth in the opinion of the Tax Court reported at 36 T.C. 852. We conclude also that the reasoning and decision of the Tax Court is correct. That decision is, therefore, affirmed on the opinion of the Tax Court.
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309 F.2d 143, 10 A.F.T.R.2d (RIA) 5841, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clarence-j-sapp-and-hilda-c-sapp-v-commissioner-of-internal-revenue-ca5-1962.