Morelan v. United States

237 F. Supp. 879, 15 A.F.T.R.2d (RIA) 340, 1965 U.S. Dist. LEXIS 9215
CourtDistrict Court, D. Minnesota
DecidedFebruary 5, 1965
Docket4-64-Civ-175, 4-64-Civ-176
StatusPublished
Cited by10 cases

This text of 237 F. Supp. 879 (Morelan v. United States) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morelan v. United States, 237 F. Supp. 879, 15 A.F.T.R.2d (RIA) 340, 1965 U.S. Dist. LEXIS 9215 (mnd 1965).

Opinion

DEVITT, Chief Judge.

The issue in these income tax refund actions brought by two Minnesota State Highway Patrol Officers is as to the tax-ability of the $3-per-day “subsistence allowance” received by them for each working day as reimbursement for meals purchased in public restaurants while in duty status, and for certain uniform maintenance and other expenses.

Jurisdiction is established. 28 U.S.C.A. § 1346(a) (1).

Plaintiff Morelan and his wife seek to recover $140.00, representing the claimed improper tax assessed and paid upon $633.00 received as subsistence allowance by Morelan in the year 1960.

Plaintiff Christey, a single man, seeks to recover $471.53 representing the claimed improper tax assessed and paid upon subsistence allowances paid to him in the sum of $114.00 in 1959, $729.00 in 1960, $774.00 in 1961 and $720.00 in 1962.

It is stipulated that plaintiffs filed timely income tax returns for the years-involved and paid the tax shown to be due on their respective returns, that timely claims for refund were filed, that more than six months elapsed before these actions were filed and that the claims were rejected by the District. Director of Internal Revenue for the District of Minnesota on June 18, 1964.

In a companion case involving Morelan’s 1961 tax, 4-63-Civ-51, the Govern *881 ment has conceded that the subsistence allowance paid Morelan was not taxable and has paid him the claimed refund.

Additional actions by other Minnesota Highway Patrolmen are pending. Two-hundred-twenty patrolmen, either by individual actions or by pending motions to intervene, seek a determination as to the taxability of their subsistence allowance for recent tax years. It is suggested that decision in these two actions will probably determine the issue as to all of them. The facts are substantially similar.

The Minnesota State Highway Patrol is an agency of the State of Minnesota and has been in existence since 1930. It has a total complement of 336 men— 220 of whom are active patrolmen. The personnel is organized along military lines. The patrolmen dress in neat-appearing maroon military type uniforms and are required to maintain a smart appearance. The Patrol’s principal responsibility is to enforce the highway traffic laws of the State, arrest offenders, direct and control traffic, provide assistance to the general public, investigate accidents and administer first aid to the injured. It also cooperates with other law enforcement agencies in the pursuit and apprehension of violators of the criminal laws.

The patrolmen are employed by the State of Minnesota under Civil Service laws and regulations. They receive a statutorily fixed salary. In addition, they now receive, and during all of the taxable years in question received, a subsistence allowance of $3 per day for each day of active duty as reimbursement for meals purchased during their tour of duty and for other expenses. They are required to eat these meals in a public restaurant adjacent to the highway and at a place which does not serve intoxicating liquors. Patrolmen are assigned specific times, periodically fixed by schedules, when they are to eat their meal or meals on a tour of duty. They are allowed one-half hour in the rural areas of the State and an hour in the metropolitan areas within which to eat their meal. They must report by radio telephone when they intend to eat and must advise the restaurant telephone number at which they may be reached during the meal period.

In the early days of the Patrol, the patrolmen were compensated for their expenses upon the rendition of a voucher showing the actual amount expended for the meal. Later, in 1934, in order to avoid bookkeeping and accounting incidental to processing these claims for reimbursement, the law was changed to provide for a subsistence of 65(5 per day. As living costs increased, this was later raised to 75(5, then to $1, then to $1.50, then to $2 and, sometime prior to 1959, to $3 per day. The $3-per-day subsistence reimbursement is intended to reimburse the officers for meals purchased during the tour of duty, for parking meter charges, the cleaning of uniforms, the purchase of uniform necessities such as ties, socks, black shoes and shoe polish, and also to reimburse the patrolman for the cost of a telephone in his home in his duty station area.

Patrolmen are subject to call 24 hours a day. A normal tour of duty is for periods of between 8% and 9 hours. Sometimes, in cases of emergency or when conducting a concentrated check on compliance with motor vehicle laws, the officers work up to 12 or more hours per day. Plaintiffs Morelan and Christey said that approximately % of their duty time is spent in night work — that is, after 5:30 in the afternoon. The officers are required to eat their meals away from home during working hours and at scheduled times — usually during light traffic periods. They travel between 140 and 300 miles per day in patrol duty.

It appeared from the evidence that a principal purpose of the requirement that the officers eat their meals at a public restaurant adjacent to a state highway was to insure public safety and obedience to law through the physical presence of the officers in uniform and to facilitate their availability to the public for the reporting of accidents and the seeking of information with reference to the traffic and motor vehicle laws of the State. Patrol officers testified that it was a com *882 •mon experience to be asked to furnish advice and to render assistance to members of the public during the time they appeared in public restaurants for their ■meals.

Officer Morelan testified that during I960 he served a five-county area in central Minnesota, was stationed at Paynes-ville, and covered 200 to 250 miles per .day in his patrol duties — principally during the night hours. He said that the •average cost of a meal purchased on duty during 1960 was $2.25. He said he spent approximately $250.00 during the average year for the cleaning of his uniform and equipment, including shirts, “blouses, pants and hat, and for the necessary purchase of 3 or 4 ties a year at :$1.50 each, 10 pairs of socks at $1.50, 2 •pairs of shoes at $20.00, and 2 or 3 pairs •of overshoes.

Officer Christey was stationed at Excel.sior during the years involved and patrolled portions of Hennepin and Carver Counties in the Twin Cities Metropolitan .area. He said he traveled between 140 and 300 miles daily, most of it during the ■night hours. He said that the expenses •for maintaining his uniform and purchasing necessary clothing was about $260.00 -per year. He detailed the expenditures.

Each officer was required to maintain a telephone at his home. The monthly charge for this varies within the state between $5 and $8 per month.

Both plaintiffs testified that they expended all, and more than, $3 per day for the purchase of meals during duty hours, the maintenance of their uniforms, the purchase of necessary and required official clothing, and the payment of the telephone expense.

The legal issue thus presented is whether the $3-a-day subsistence allowance is taxable income.

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Related

Koerner v. United States
404 F. Supp. 1128 (S.D. West Virginia, 1975)
Kowalski v. Comm'r
65 T.C. 44 (U.S. Tax Court, 1975)
Ghastin v. Commissioner
60 T.C. No. 31 (U.S. Tax Court, 1973)

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Bluebook (online)
237 F. Supp. 879, 15 A.F.T.R.2d (RIA) 340, 1965 U.S. Dist. LEXIS 9215, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morelan-v-united-states-mnd-1965.