Legal Opinion

Marlin v. Commissioner

United States Tax Court

Decided March 23, 1970No. Docket No. 3817-69SCPublished

Petitioners, husband and wife, were employed as a Latin and a world history teacher, respectively, in New York City high schools during 1966. In the summer of that year they traveled throughout France for about 8 weeks.

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Petitioners, husband and wife, were employed as a Latin and a world history teacher, respectively, in New York City high schools during 1966. In the summer of that year they traveled throughout France for about 8 weeks. Held, that the husband has failed to establish that the major portion of the activities during such travel was directly and proximately related to skills required of him as a Latin teacher and, therefore, the travel expenses attributed to him are not deductible as ordinary and necessary business expenses. Held, further, that the major portion of the activities during such…

1Opinion of the Court

Stanley and Edith Marlin, Petitioners v. Commissioner of Internal Revenue, Respondent

Marlin v. Commissioner

Docket No. 3817-69SC

United States Tax Court

54 T.C. 560; 1970 U.S. Tax Ct. LEXIS 186;

March 23, 1970, Filed

Decision will be entered under Rule 50.

Petitioners, husband and wife, were employed as a Latin and a world history teacher, respectively, in New York City high schools during 1966. In the summer of that year they traveled throughout France for about 8 weeks. Held, that the husband has failed to establish that the major portion of the activities during such travel was directly and…

2Cases cited9 opinions

  1. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  2. Weiszmann v. CommissionerUnited States Tax Court · 1969
  3. Carroll v. CommissionerUnited States Tax Court · 1968
  4. James A. And Isabelle Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
  5. Ephraim Cross and Mary Cross v. United StatesCourt of Appeals for the Second Circuit · 1964

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