Thomas P. Dennehy v. Commissioner of Internal Revenue

ORDER

While technically presenting issues concerning the petitioning taxpayer’s right to a refund for the year in question (1955) and the propriety of a deficiency assessed by the Commissioner of Internal Revenue for the same year, the single question submitted by this appeal from the Tax Court is whether the taxpayer, a university mathematics instructor, may deduct expenses he incurred in European travel during his “sabbatical summer” as an “ordinary and necessary” business expense under Section 162(a) of the Internal Revenue Code of 1954, 26 U.S.C.A. § 162(a).

The record discloses that…