Craig v. Commissioner
United States Tax Court
P, a flight engineer for Eastern Airlines, took a course to obtain an airline transport pilot certificate. Held, the cost of such course was not deductible as an educational expense under section 1.162-5, Income Tax Regs., because the course was part of a program of study which would lead to qualifying P in a new trade or business.
1Opinion of the Court
ROBERT E. CRAIG and KATHLEEN CRAIG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Craig v. Commissioner
Docket No. 20630-81.
United States Tax Court
T.C. Memo 1983-631; 1983 Tax Ct. Memo LEXIS 157; 47 T.C.M. (CCH) 27; T.C.M. (RIA) 83631;
October 12, 1983.
P, a flight engineer for Eastern Airlines, took a course to obtain an airline transport pilot certificate. Held, the cost of such course was not deductible as an educational expense under section 1.162-5, Income Tax Regs., because the course was part of a program of study which would lead to qualifying P in a new trade or business.
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2Cases cited5 opinions
- Davis v. CommissionerUnited States Tax Court · 1976
- Manocchio v. CommissionerUnited States Tax Court · 1982
- John Manocchio v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Bodley v. CommissionerUnited States Tax Court · 1971
- Robinson v. CommissionerUnited States Tax Court · 1982