Furner v. Comm'r
United States Tax Court
Held, petitioner is not entitled to a deduction for her expenditures for full-time graduate study which she undertook after she resigned from a position as a social studies teacher in a Minnesota junior high school and prior to commencing teaching social studies in an Illinois junior high school.
1DissentSimpson, J.
I must dissent from the opinion of the majority in all respects. I believe that the majority takes too restrictive a view of the “trade or business” of teaching, and I do not understand how the majority can disregard the forthright and obviously sincere testimony of the petitioner and find that her primary purpose was to obtain a position about which she knew nothing.
The majority seems to feel that if one is not being paid for actively conducting classes, he is not in the trade or business of teaching. I disagree. Effective teaching requires that a teacher keep abreast of new developments in…
2Cases cited9 opinions
- Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- Ashby H. Canter and Florence G. Canter v. The United StatesUnited States Court of Claims · 1965
- Hill v. CommissionerUnited States Tax Court · 1949
- Marlor v. CommissionerUnited States Tax Court · 1956
- Marlor v. CommissionerCourt of Appeals for the Second Circuit · 1958
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