Seibold v. Commissioner
United States Tax Court
Petitioners, in the summer of 1952, took a European travel tour, lasting approximately 2 months, at a cost of $ 1,245 each. The itinerary included stays in France, Italy, Switzerland, and England, with extensive visits to places of interest in each country. One of the petitioners, who was teaching under a temporary certificate, attended a 2 weeks course at Geneva and was given 6 hours' credit toward a permanent certificate.
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Petitioners, in the summer of 1952, took a European travel tour, lasting approximately 2 months, at a cost of $ 1,245 each. The itinerary included stays in France, Italy, Switzerland, and England, with extensive visits to places of interest in each country. One of the petitioners, who was teaching under a temporary certificate, attended a 2 weeks course at Geneva and was given 6 hours' credit toward a permanent certificate. This same petitioner in 1952 attended universities in New York City where she earned 26 credits toward her permanent teaching certificate. The other petitioner, also a…
1Opinion of the Court
Mulroney, Judge:
Respondent determined a deficiency in the income tax of petitioners for 1952 in the sum of $1,051.62 and additions thereto under section 294 (d) (1) (A) and (d) (2), I. R. C. 1939, in the amounts of $56.92 and $34.16, respectively.
The question presented is whether petitioners were entitled, under the provisions of section 23 (a) (1) (A), I. R. C. 1939, to a deduction of $3,224.25 in the year 1952, as educational expenses.
FINDINGS OF FACT.
Some of the facts were stipulated and they are found accordingly. Petitioners, Richard and Melba Y. Seibold, are husband and wife who reside…
2Cases cited5 opinions
- Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- Hill v. CommissionerUnited States Tax Court · 1949
- Cardozo v. CommissionerUnited States Tax Court · 1951
- Kamins v. CommissionerUnited States Tax Court · 1956
- Green v. CommissionerUnited States Tax Court · 1957
3Cited by11 opinions
- Ben H. Adelson and Nancy R. Adelson v. United StatesCourt of Appeals for the Ninth Circuit · 1965
- Davis v. CommissionerUnited States Tax Court · 1962
- Belaval v. Secretario de HaciendaSupreme Court of Puerto Rico · 1961
- Adelson v. United StatesDistrict Court, S.D. California · 1963
- Anzalone v. CommissionerUnited States Tax Court · 1964
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