Bissonnette v. Commissioner
United States Tax Court
127 T.C. 124 (2006)
- Written by Joe Cox, JD
Facts
Marc Bissonnette (plaintiff) was a ferryboat captain in Washington. Bissonnette had attended the Merchant Marine Academy, had lengthy experience as a captain, and served as captain of boats with up to 1,200 passengers for whose safety Bissonnette was constantly responsible. Bissonnette usually worked 15-to-17-hour days. During off-season voyages, each day’s turnaround included a layover of about six hours at a port in Victoria, Washington. During those layovers, Bissonnette usually had lunch, took a brief swim, and then returned to the ship to nap on a cot for about four hours. During peak-season trips, the layover was only about a half hour or an hour. Bissonnette reported his meals and incidental expenses as itemized deductions on Bissonnette’s federal income taxes. The Commissioner of Internal Revenue (defendant) denied the deductions, arguing that Bissonnette was not actually away from home because the voyages did not require Bissonnette to obtain sleep or rest but were rather the product of scheduling quirks. Bissonnette then filed suit, arguing that he was required to obtain sleep or rest and entitled to Bissonnette’s claimed deductions.
Rule of Law
Issue
Holding and Reasoning (Haines, J.)
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