Estate of Rockefeller v. Commissioner
United States Court of Appeals for the Second Circuit
762 F.2d 264 (1985)
Relevant factsFree
After retiring as New York's governor and chairing two policy commissions without executive duties, Rockefeller (plaintiff) was nominated for vice president following Nixon's sudden resignation and deducted his confirmation-related costs as business expenses, but the Commissioner (defendant) disallowed the deduction, finding no substantial similarity between his non-executive commission chairmanships and the vice presidency, and the Tax Court agreed.
IssueFree
Whether a federal taxpayer may deduct business expenses incurred to change positions with substantially similar job duties within the same trade or business.