Bakken v. Commissioner
United States Tax Court
Petitioner, while employed as a full-time engineer at the Sandia Corp., enrolled in an evening law school course of study leading to the degree of juris doctor. His subjective purpose in studying law was to develop the abilities of logical reasoning and self-expression, the development of which was necessary if petitioner was to maintain his job status at Sandia.
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Petitioner, while employed as a full-time engineer at the Sandia Corp., enrolled in an evening law school course of study leading to the degree of juris doctor. His subjective purpose in studying law was to develop the abilities of logical reasoning and self-expression, the development of which was necessary if petitioner was to maintain his job status at Sandia. Held, the expenditures for the education are not deductible under sec. 162(a), I.R.C. 1954, as the education was not directly and proximately related to petitioner's employment; the expenditures were not for education undertaken…
1Opinion of the Court
TietjeNS, Judge:
The Commissioner determined deficiencies in income tax of petitioner in the amounts of $349 and $394.48, respectively, for the years 1965 and 1966. We must decide whether petitioner may deduct certain educational expenses.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation and the exhibits attached thereto are incorporated herein by this reference.
At the time he filed his petition in docket No. 2327-67, Lawrence H. Baldeen (hereinafter referred to as Lawrence) resided in Dublin, Calif. He resided in Livermore, Calif., at the time he filed…
2Cases cited3 opinions
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Carroll v. CommissionerUnited States Tax Court · 1968
- Henry v. CommissionerUnited States Tax Court · 1961
3Cited by13 opinions
- Glasgow v. CommissionerUnited States Tax Court · 1972
- Menas v. CommissionerUnited States Tax Court · 1969
- Baker v. CommissionerUnited States Tax Court · 1971
- Bakken v. CommissionerUnited States Tax Court · 1969
- Coughlin v. CommissionerUnited States Tax Court · 1969
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