Ford v. Commissioner
United States Tax Court
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
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Primuth v. CommissionerUnited States Tax Court · 1970
- Carlucci v. CommissionerUnited States Tax Court · 1962
- 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
- Davis v. CommissionerUnited States Tax Court · 1976
- Boser v. CommissionerUnited States Tax Court · 1981
- O'Donnell v. CommissionerUnited States Tax Court · 1974
- John C. Ford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1973
- Reisinger v. CommissionerUnited States Tax Court · 1979
50 more not listed; retrieve them via the Exa API.