Sibla v. Commissioner
United States Court of Appeals for the Ninth Circuit
611 F.2d 1260 (1980)
Richard Sibla and Robert Cooper (plaintiffs) worked for the Los Angeles Fire Department as firemen. As conditions to their employment, the firemen worked 24-hour shifts, were not allowed to leave the station house on personal errands, and were required to participate in a nonexclusionary organized mess at the station house for all meals during their shift. The only way to receive an exclusion to mess requirement was if the Los Angeles examining physician verified a fireman’s physical ailment. The fire department established the mess plan and likely directed the appointment and compensation of the chef. While the chef used the kitchen at the station house, the firemen collectively paid for the food and kitchen materials used. The firemen also assessed and collected from each other the cost of the meals provided without consideration of whether they were present for the meal. Sibla in 1972 and Cooper in 1972 and 1973 deducted their total mess assessments as ordinary and necessary business expenses under Internal Revenue Code § 162(a). The Internal Revenue Commissioner (the commissioner) (defendant) disallowed their deductions on the basis that the mess assessments were nondeductible personal expenses. When challenged, the United States Tax Court ruled in favor of Sibla and Cooper. The commissioner appealed.
Rule of Law
Holding and Reasoning (Curtis, J.)
Dissent (Kennedy, J.)
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