Legal Opinion

Brown v. Commissioner

United States Tax Court

Decided October 24, 1979No. Docket Nos. 8592-77, 11685-77Published

In order to provide a better education for her son in a safer environment, and in order to free herself to seek and hold gainful employment, petitioner enrolled her 13-year old son in boarding school. She considered herself unable to work while her son remained in public school due to constantly arising problems (teacher strikes, classroom disorders, and gang fights) at the public school.

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In order to provide a better education for her son in a safer environment, and in order to free herself to seek and hold gainful employment, petitioner enrolled her 13-year old son in boarding school. She considered herself unable to work while her son remained in public school due to constantly arising problems (teacher strikes, classroom disorders, and gang fights) at the public school. Held, such portion of the boarding school costs as is allocable to child care rather than to education was deductible for 1974 and 1975 under sec. 214(b)(2), I.R.C. 1954, as expenses for child care incurred…

1Opinion of the Court

Goldie O. Brown, Petitioner v. Commissioner of Internal Revenue, Respondent

Brown v. Commissioner

Docket Nos. 8592-77, 11685-77 1

United States Tax Court

73 T.C. 156; 1979 U.S. Tax Ct. LEXIS 31;

October 24, 1979, Filed

Decision will be entered under Rule 155.

In order to provide a better education for her son in a safer environment, and in order to free herself to seek and hold gainful employment, petitioner enrolled her 13-year old son in boarding school. She considered herself unable to work while her son remained in public school due to constantly arising problems (teacher strikes, classroom…

Also in this document: Dissent · Drennen; Dissent · Tannenwald.

2Cases cited5 opinions

  1. Fausner v. CommissionerSupreme Court of the United States · 1973
  2. Reese v. CommissionerUnited States Tax Court · 1966
  3. Jungreis v. CommissionerUnited States Tax Court · 1970
  4. Brown v. CommissionerUnited States Tax Court · 1979
  5. Limpert v. CommissionerUnited States Tax Court · 1961

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