Corbett v. Commissioner
United States Tax Court
In 1966, the petitioner resigned her position as teacher of Germanic languages and commenced full-time study leading to a Ph.D. degree in that field. Held, expenditures incurred by the petitioner in connection with graduate studies in 1967 are nondeductible personal expenses. The petitioner failed to prove that she was engaged in carrying on a trade or business within the meaning of sec. 162(a), I.R.C. 1954.
1Opinion of the Court
Simpson, Judge-.
The respondent determined a deficiency of $401.23 in the petitioners’ 1967 Federal income tax. The issue for decision is whether the petitioner was carrying on a trade or business within the meaning of section 162(a) of the Internal Bevenue Code of 19541 while she was pursuing a course of study leading to a Ph.D. degree.
BINDINGS OB PACT
Some of the facts have been stipulated, and those facts are so found.
The petitioners, Peter G. Corbett and Amaryllis E. Corbett, are husband and wife, who maintained their legal residence in Biverdale, N.Y., at the time of filing their petition…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Frank v. CommissionerUnited States Tax Court · 1953
- Bedell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929
- Koons v. CommissionerUnited States Tax Court · 1961
- Morton v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
5 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Davis v. CommissionerUnited States Tax Court · 1976
- Ford v. CommissionerUnited States Tax Court · 1971
- Reisinger v. CommissionerUnited States Tax Court · 1979
- Wassenaar v. CommissionerUnited States Tax Court · 1979
- Wyatt v. CommissionerUnited States Tax Court · 1971
37 more not listed; retrieve them via the Exa API.