¶1dissenting: I do not think the fact that the taxpayer here accepted employment first in Lockheed’s Washington office with the understanding he would be moved at company expense within a few weeks to Burbank, distinguishes this case from United States v. Woodall, 255 F. 2d 370, certiorari denied 358 U.S. 824, or Hedberg v. United States, - F. Supp. - (W.D. Wash., Mar. 10, 1961). From all that appears, the employment in Washington was an interim arrangement primarily to allow time for the taxpayer’s wife to give birth, albeit the taxpayer was thereby given an opportunity to learn something of his employer’s operation. This should not keep the taxpayer from being a new employee at Burbank and I think the expenses of moving there were reimbursed personal expenses and properly in-cludible in gross income.
36 T.C. 300
Cavanagh v. Commissioner
Decided May 18, 1961
United States Tax Court · decided 1961-05-18
Petitioner entered the employment and worked in the Washington office of Lockheed Aircraft Corporation with the understanding that he would later be transferred to his employer's place of business in… Held: that the expenses incidental to the petitioner's transfer to the Burbank office, all of which were borne by the corporation, did not constitute taxable income to the petitioner.
Cited by 15 later decisions — most recently December 1968
3 federal appellate ·
Relies on Abel v. United States · United States v. Woodall
Good law ✅— No negative treatment on recordhow we know
Decision will be entered under Rule 50 · Decided 1961-05-18
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