Browne v. Commissioner
United States Tax Court
Held: 1. Costs of obtaining a bachelor's degree in accounting not deductible because the expenses were incurred to meet the minimum educational requirement for qualification in petitioner's trade or business and the education qualified petitioner for a new trade or business.
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Held: 1. Costs of obtaining a bachelor's degree in accounting not deductible because the expenses were incurred to meet the minimum educational requirement for qualification in petitioner's trade or business and the education qualified petitioner for a new trade or business. Sec. 1.162-5(b), Income Tax Regs. 2. In computing a home office expense deduction, petitioner must allocate the rental expense on the basis of time actually so used by comparing the days of business use with the time actually used for all purposes. 3. Petitioner's expenses attributable to self-employment approximated.…
1Opinion of the Court
Irwin, Judge:
Respondent determined a deficiency of $1,253 in petitioner’s 1975 Federal income tax. Due to adjustments agreed to by the parties, the only issues presented are as follows:(1) Whether expenses in the amount of $3,577 paid by petitioner during 1975 for an education in obtaining a bachelor’s degree, with a major in accounting, are allowable deductions under section 162;1(2) Whether petitioner should be allowed to deduct under section 162 a portion of her rent as a home office expense in excess of the amount allowed by respondent;(3) Whether a loss claimed from petitioner’s business…
Also in this document: Dissent.
2Cases cited11 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Wickwire v. ReineckeSupreme Court of the United States · 1927
- International Artists, Ltd. v. CommissionerUnited States Tax Court · 1970
- Swanson v. CommissionerUnited States Tax Court · 1976
6 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- Vons Companies, Inc. v. United StatesUnited States Court of Federal Claims · 2001
- Crow v. CommissionerUnited States Tax Court · 1985
- Gantner v. CommissionerUnited States Tax Court · 1988
- Goldsboro Art League, Inc. v. CommissionerUnited States Tax Court · 1980
- Estate of Smead v. CommissionerUnited States Tax Court · 1982
51 more not listed; retrieve them via the Exa API.