From Business: About Lako Tool With more than 30 years of experience, Lako Tool serves the packaging industry with sealing, cutting and punching solutions. We manufacture…. Website Directions More Info. We found 79 results 1 2 3 Next. Jay testified that he "Made out reports for clients, the recommendations of work proposed, or to be done, or done for clients, procedures, designed the forms, generator plant layouts, and the general paperwork involved in professional engineering" in Greenville, but he did not relate that statement to any work done during the taxable years. However, with respect to realigning machinery for Lau-Blower in , he testified, "Now, the plant layout and the majority of all the paper work was not done in Dayton.
The leg work, the time studies, were done at the plant, as is normal; but the other work was all taken back to my office in Greenville. This, taken in connection with other evidence, leads the Court to doubt that he could have done very much, if any, of his work during the taxable years at his place in Greenville. But even if he did do some work there, certainly by far the largest part of the work which he did to earn income during these taxable years was done in Dayton, and all of it could have been done there without travel expense had he resided there.
He may have worked only 1 month in yet was in Dayton days. Jay testified in explanation of the Dayton addresses which he used in his business, "Well, through analysis of our ethical way of contacting clients, I found that I got very few responses to Greenville, but that by having an answering service and a mail service where mail could reach me in a city like Dayton, I got a very much greater response, and contacts for my profession. The evidence as a whole implies that Jay's only prospects of employment were in Dayton and that he, like his wife, chose to live in Greenville for personal reasons only, while earning income in Dayton.
Their work in Dayton does not give rise to business expenses under the circumstances shown in this record, even though Jay depended upon short-period employment.
If the record does not prove affirmatively that Dayton was Jay's home for tax purposes, nevertheless, the petitioners have failed to sustain their burden of proof that it was not. In this, as in many cases, the purpose of the law is a valuable aid to interpretation. The broad purpose of Congress in enacting section a 2 of the Code of was to implement, in a practical way, its recognition of the fact that when the exigencies of business call for travel away from home, such travel usually entails expenses such as hotel bills, extra cost of meals, and transportation expenses not required at home.
Leaving aside, for the moment, the question of whether or not the taxpayer traveled "away from home," the stipulated facts show payments for hotel room and meals, together with at least some transportation expense. The relationship of these expenses to his business activities is apparent from the record. The taxpayer has thus brought himself within the practical application of the law at least to the point of demonstrating actual payment of expenses.
To my mind, the only real question in this case is whether taxpayer was "away from home.
Run a search by name for anyone in Toledo, Ohio & get free white pages information instantly. Toledo, Ohio white page directory listings include full name, . Lookup People, Phone Numbers, Addresses & More in Toledo, OH. Whitepages is the largest and most trusted online phone book and directory.
Flowers, U. For authorities and rulings relating thereto, see notes 4 and 5 and cases cited by the Court in Flowers, on pages It is stipulated that taxpayer resided in Greenville during the years in question. The testimony establishes that in the years in question he had an office in Greenville, and the majority, in its findings, describes the contents and uses thereof.
That he went to Dayton in pursuit of his business in and is clear upon the record. The incurring of hotel expenses in a Dayton hotel when his residence was in Greenville lends some color to the view that he was not in an "at home" status at that time. These circumstances, to my mind, make out a prima facie case on the issues in controversy and meet any technical burden of proving that taxpayer traveled "away from home" in pursuit of his business. I agree that this Court is not bound to accept a prima facie case as conclusive.
We may find other supervening circumstances which require a contrary conclusion even though as here there is no conflicting evidence. Petitioner had arrangements with a telephone- and mail-answering service in Dayton.
These are facts to be considered, but to my mind are of little significance, particularly when he had no office in Dayton and did not receive or confer with clients at the answering service office. I see no greater significance to the several addresses on his stationery and returns. Working at the plants could not, of itself, change his home to Dayton. If a taxpayer's home automatically follows a temporary jobsite, no working man could ever be away from home while he was working.
In the instant case, it seems clear to me that he went to Dayton and remained there temporarily in pursuit of his own business to carry out short-term, impermanent assignments. Without going into details, I think it is clear that the use of the hotel was required by the exigencies of his business.
It was obviously not his home. Actually, if petitioner had raised the point, I think he would be entitled to deduct part of the hotel expense as rent under section a 3 , whether in travel status or not, in view of its use for conferences as described in the findings of the majority. Pfoutz, Phil Steitz. Your Home Paradise for Gyps!
NOTE: The following folders may contain newspaper clippings, magazine articles, brochures, pamphlets, correspondence, and annotations of articles on the following subjects. Folders range in dates from May to Sept. Burglaries, self defense, consumer awareness. Burglaries, etc. Eavesdropping, con't. Gags, etc. Gambling, con't. Gimmicks and trick weapons.
Gimmicks, con't. Miscellaneous idea clippings.
Ayers, Eben A. April - May, Issued for and Correspondence, handwritten notes, memorandums, newspaper clippings, press releases, printed materials and transcripts pertaining to the book Mr. Flood: Data, Ohio, January - February, Executive Committee. Connecticut, Hartford: October
Police and Detectives at Work. Police Procedure and Records. Police Procedure, con't. Psychology, etc. Rackets, etc. Science in Detection, cont'd: news clippings, sketches, notes. Secret Service, Treasury Dept. Handwritten notes, annotations, clippings on carnivals and amusement parks. Handwritten research notes on car theft. Typewritten annotations on mining.
Clippings: wild animal training. Clippings on betting; horse race programs. Annotations, clippings on animals. Handwritten notes on wrestling. Carbon copies: Secret Service counterfeiting case reports. Story idea clippings [most on crime. Uniform Crime Reports bulletin, Vol. Articles, clippings from front inside cover of scrapbook. Article from back inside cover of scrapbook, "My Life Inside the Mob". Scrapbook containing articles on crime and detection.
Series V con't. Cole Publishing Co. Steve Roper comic books.
NOTE: All correspondence that follows may contain partial scripts for the strip by Saunders within the text of the correspondence. Anderson to Andriola [critiquing the artwork of the strip, sample panels are attached]. Saunders: "Liquor Ring Episode" synopsis. Series VI con't. Subseries B: Reader mail. Subseries C: Clippings of and about Kerry Drake comic strip.
April - Sept. Subseries D: Story Ideas. Saunders: hand and typewritten notes; miscellaneous news clippings for story ideas. Saunders and from Andriola; hand and typewritten notes, correspondence, and miscellaneous news clippings and magazine articles for story ideas. Schultz top secret policeman. Kerry Drake comic books. Kerry Drake screen treatment by Malvin Wald;. General reader mail correspondence.
Shannon, Director, National Assn.