Robertson v. Commissioner
United States Tax Court
Held, that the cost of education undertaken by the petitioner, an assistant professor of economics at a university, for the purpose of obtaining a doctoral degree is deductible as an ordinary and necessary business expense under section 162(a) of the Internal Revenue Code of 1954 and the regulations promulgated thereunder, such education having been undertaken primarily for the purpose of meeting the express requirements of his employer imposed as a condition to the…
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Held, that the cost of education undertaken by the petitioner, an assistant professor of economics at a university, for the purpose of obtaining a doctoral degree is deductible as an ordinary and necessary business expense under section 162(a) of the Internal Revenue Code of 1954 and the regulations promulgated thereunder, such education having been undertaken primarily for the purpose of meeting the express requirements of his employer imposed as a condition to the retention by the petitioner of his position as assistant professor and not for the purpose of meeting minimum requirements for…
1Opinion of the Court
Atkins, Judge:
The respondent determined a deficiency in income tax in the amount of $249.17 for the taxable year 1958. The sole issue for decision is whether the petitioner, an assistant professor of economics at the University of Nebraska, is entitled to deduct as ordinary and necessary business expenses under section 162(a) of the Internal Revenue Code of 1954 amounts expended in attending the University of Michigan for the purpose of completing work prerequisite to obtaining a Ph. D. degree.
Some of the facts are stipulated and are incorporated herein by this reference.
FINDINGS OF FACT.
The…
2Cases cited5 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- Booth v. CommissionerUnited States Tax Court · 1961
- Kamins v. CommissionerUnited States Tax Court · 1956
- Green v. CommissionerUnited States Tax Court · 1957
3Cited by9 opinions
- Denman v. CommissionerUnited States Tax Court · 1967
- Lund v. CommissionerUnited States Tax Court · 1966
- Denman v. CommissionerUnited States Tax Court · 1967
- Hester v. CommissionerUnited States Tax Court · 1963
- Killips v. CommissionerUnited States Tax Court · 1963
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