Baker v. Commissioner
United States Tax Court
Petitioner, after graduating from college, began working full time in March 1964 for his father's construction company as an engineer. From September 1964 until March 1967 he was a full-time law student, and during this period worked part time for the construction company. Upon graduation from law school he again became a full-time employee of the construction company. He was immediately elected to the position of vice president with a substantial increase in salary.
Read the full summary
Petitioner, after graduating from college, began working full time in March 1964 for his father's construction company as an engineer. From September 1964 until March 1967 he was a full-time law student, and during this period worked part time for the construction company. Upon graduation from law school he again became a full-time employee of the construction company. He was immediately elected to the position of vice president with a substantial increase in salary. Held, that the study of law was undertaken by petitioner primarily for personal purposes and, therefore, the expenses he…
1Opinion of the Court
Dawson, Judge:
Respondent determined deficiencies in petitioner’s income tax for the years 1964 and 1965 in the respective amounts of $339.69 and $994.43.
For the year 1964, petitioner has conceded in his reply brief that Re is not entitled to deductions for automobile expense of $40 and for tuition, books, and supplies of $535.61. Thus there remains in dispute a claimed business deduction of $1,030.50 for meals and lodging incurred while petitioner was attending the University of Denver Law School.
Petitioner did not allege error in his petition with respect to a claimed deduction of $4,278.87…
2Cases cited4 opinions
- Booth v. CommissionerUnited States Tax Court · 1961
- Martin J. Welsh and Elsie N. Welsh v. United StatesCourt of Appeals for the Sixth Circuit · 1964
- Sandt v. CommissionerCourt of Appeals for the Third Circuit · 1962
- James J. Condit and Rose Marie Condit v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
3Cited by43 opinions
- Bodley v. CommissionerUnited States Tax Court · 1971
- Boser v. CommissionerUnited States Tax Court · 1981
- Schwartz v. CommissionerUnited States Tax Court · 1978
- Bradley v. CommissionerUnited States Tax Court · 1970
- Wassenaar v. CommissionerUnited States Tax Court · 1979
38 more not listed; retrieve them via the Exa API.