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Year Deficiency
1990 $6,400.27
1991 5,841.34
1992 3,922.00
The issue for decision is whether reimbursement by the State of
Mississippi for certain travel, lodging, and meal expenses incurred
by James Lawton Robertson (petitioner) during his term as a Justice
of the Mississippi Supreme Court is excludable from petitioners'
income. To the extent petitioner incurred unreimbursed travel,
lodging, and meal expenses, we must also decide whether those
expenses are deductible from petitioners' income.
Unless otherwise indicated, all section references are to the
Internal Revenue Code as in effect for the years in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
At the time the petition was filed, petitioner resided in
Jackson, Mississippi, and petitioner's wife, Lillian Janette Humber
Robertson (Mrs. Robertson), resided in Oxford, Mississippi.
Petitioner's Appointment and Election as a Justice to the
Mississippi Supreme Court
In 1965, petitioner began practicing law in Greenville,
Mississippi. In 1979, petitioner became a full-time law professor
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