Lamb v. Commissioner
United States Tax Court
Petitioner, who was an electrical engineer employed by IBM, voluntarily applied for the position of patent trainee in IBM's patent training program, a program designed to qualify eligible applicants for the position of patent attorney or agent with IBM. Petitioner was aware at the time of application for the position of patent trainee that he would be required, as a part of the program, to attend law school and maintain requisite progress toward obtaining an LL.B. degree.
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Petitioner, who was an electrical engineer employed by IBM, voluntarily applied for the position of patent trainee in IBM's patent training program, a program designed to qualify eligible applicants for the position of patent attorney or agent with IBM. Petitioner was aware at the time of application for the position of patent trainee that he would be required, as a part of the program, to attend law school and maintain requisite progress toward obtaining an LL.B. degree. Petitioner was accepted into the program, attended law school, received his degree, and was then employed as a patent…
1Opinion of the Court
Simpson, Judge:
Respondent determined a deficiency in income tax for the taxable year 1962 of $194.99. The only issue for decision is whether petitioner’s expenses incurred and paid in 1962 for tuition and books hi attending law school are deductible under section 162(a) of the Internal Revenue Code of 19541 as ordinary and necessary expenses of carrying on a trade or business.
FINDINGS OP PACT
Some of the facts were stipulated, and those facts are so found.
Petitioners, Owen L. Lamb and Nancy G. Lamb, are individuals, husband and wife, residing at 16 Sheldon Drive, Poughkeepsie, N.Y. They filed…
2Cases cited4 opinions
- Sandt v. CommissionerCourt of Appeals for the Third Circuit · 1962
- Marlor v. CommissionerUnited States Tax Court · 1956
- Marlor v. CommissionerCourt of Appeals for the Second Circuit · 1958
- Williams v. United StatesDistrict Court, S.D. New York · 1965
3Cited by8 opinions
- Weiszmann v. CommissionerUnited States Tax Court · 1969
- Owen L. Lamb and Nancy G. Lamb v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1968
- Louis H. Rombach and Ann M. Rombach v. The United StatesUnited States Court of Claims · 1971
- Jones v. CommissionerUnited States Tax Court · 1970
- Kinch v. CommissionerUnited States Tax Court · 1971
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