Legal Opinion

Mason v. Commissioner

United States Tax Court

Decided July 1, 1982No. Docket No. 9518-80UnpublishedCited by 9 opinions

P was a pilot of a C-130 in the Air National Guard. He took flight training courses which led to his obtaining an FAA flight engineer's certificate for the Boeing 727 and an airline transport pilot certificate for the C-130. Held, the expenses of the flight engineer course are not deductible as ordinary and necessary business expenses since such training did not maintain or improve the skills required by P in his employment as a pilot, and such training led to P's qualifying…

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P was a pilot of a C-130 in the Air National Guard. He took flight training courses which led to his obtaining an FAA flight engineer's certificate for the Boeing 727 and an airline transport pilot certificate for the C-130. Held, the expenses of the flight engineer course are not deductible as ordinary and necessary business expenses since such training did not maintain or improve the skills required by P in his employment as a pilot, and such training led to P's qualifying for a new trade or business. Held, further, the obtaining of an airline transport pilot certificate was not a minimum…

1Opinion of the Court

NATHAN L. MASON and YVONNE E. MASON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Mason v. Commissioner

Docket No. 9518-80

United States Tax Court

T.C. Memo 1982-376; 1982 Tax Ct. Memo LEXIS 371; 44 T.C.M. (CCH) 365; T.C.M. (RIA) 82376;

July 1, 1982

P was a pilot of a C-130 in the Air National Guard. He took flight training courses which led to his obtaining an FAA flight engineer's certificate for the Boeing 727 and an airline transport pilot certificate for the C-130. Held, the expenses of the flight engineer course are not deductible as ordinary and necessary business expenses…

2Cases cited16 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Kornhauser v. United StatesSupreme Court of the United States · 1928
  3. Davis v. CommissionerUnited States Tax Court · 1976
  4. Weiszmann v. CommissionerUnited States Tax Court · 1969
  5. Carroll v. CommissionerUnited States Tax Court · 1968

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

3Cited by9 opinions

  1. Campbell v. CommissionerUnited States Tax Court · 1983
  2. Forrest v. CommissionerUnited States Tax Court · 1983
  3. Gruman v. CommissionerUnited States Tax Court · 1982
  4. Harman v. CommissionerUnited States Tax Court · 1983
  5. Jackson v. CommissionerUnited States Tax Court · 1983

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

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