Legal Opinion

Larson v. Commissioner

United States Tax Court

Decided December 28, 1950No. Docket No. 23311PublishedCited by 13 opinions

Expenses incurred for evening engineering courses, held not deductible by petitioner, who was employed during the tax year in an engineering capacity. Hill v. Commissioner (CA-4), 181 Fed. (2d) 906, distinguished.

1Opinion of the Court

OPINION.

Opper, Judge:

Petitioner’s claim to be entitled to a deduction as

“engineering expenses” of sums paid for tuition and other outlays in connection with attendance at a university must be disallowed as being expenditures “for educational purposes and of a personal character.” Appeal of T. F. Driscoll, 4 B. T. A. 1008; see also O. D. 892, 4 C. B. 209 (1921); O. D. 984, 5 C. B. 171 (1921). “Reputation and learning are akin to capital assets, like the good will of an old partnership * * * For many, they are the only tools with which to hew a pathway to success. The money spent in acquiring…

2Cases cited2 opinions

Welch v. HelveringSupreme Court of the United States · 1933
Hill v. CommissionerUnited States Tax Court · 1949

3Cited by13 opinions

Denman v. CommissionerUnited States Tax Court · 1967
Marlor v. CommissionerUnited States Tax Court · 1956
Kamins v. CommissionerUnited States Tax Court · 1956
Thomas P. Dennehy v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1962
Aronin v. CommissionerUnited States Tax Court · 1961

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