Legal Opinion

Ford v. Commissioner

United States Tax Court

Decided September 15, 1971No. Docket No. 3996-70PublishedCited by 55 opinions

Petitioner taught remedial English and developmental reading under a provisional credential from the State of California until June 1967. In August 1967 he went to Norway for 1 year and studied anthropology and linguistics at the University of Oslo. In the fall of 1967 he applied for work with USDESEA as a substitute teacher, and taught 1 day in December.

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Petitioner taught remedial English and developmental reading under a provisional credential from the State of California until June 1967. In August 1967 he went to Norway for 1 year and studied anthropology and linguistics at the University of Oslo. In the fall of 1967 he applied for work with USDESEA as a substitute teacher, and taught 1 day in December. He applied in late 1967 for employment with California schools to begin in the fall of 1968, and began teaching English and social studies in a high school in September 1968. Held, (1) petitioner was in the trade or business of teaching…

1Opinion of the Court

Dawson, Judge:

This case was heard in Los Angeles by Commissioner Charles E. Johnston. We have adopted his findings of fact and conclusions.

Eespondent determined a deficiency of $274 in petitioner’s Federal income tax for the year 1967. At issue is whether petitioner is entitled to a deduction under section 162(a), I.E.C. 1954, and the regulations promulgated thereunder, for certain expenses incurred by him when he undertook a course of graduate study at the University of Oslo- in Norway in the fall of 1967. The answer depends upon (1) whether he was engaged in the trade or business of…

2Cases cited13 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Primuth v. CommissionerUnited States Tax Court · 1970
  4. Carlucci v. CommissionerUnited States Tax Court · 1962
  5. Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950

8 more not listed; retrieve them via the Exa API.

3Cited by55 opinions

  1. Davis v. CommissionerUnited States Tax Court · 1976
  2. Boser v. CommissionerUnited States Tax Court · 1981
  3. O'Donnell v. CommissionerUnited States Tax Court · 1974
  4. John C. Ford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1973
  5. Reisinger v. CommissionerUnited States Tax Court · 1979

50 more not listed; retrieve them via the Exa API.

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