Legal Opinion

Davis v. Commissioner

United States Tax Court

Decided April 30, 1962No. Docket No. 85651PublishedCited by 12 opinions

1. Expenses incurred by college professor on European trip undertaken for research and study held not deductible as business expenses. Manoel Cardozo, 17 T.C. 3, followed. 2. Expenses of maintaining a study at petitioner's home and depreciation relating thereto held not deductible.

1Opinion of the Court

OPINION.

Fat, Judge:

The first question is whether the $2,016.19 expended by petitioner for the European trip in 1956 is deductible as an ordinary and necessary expense incurred in the pursuit of his trade or business under the provisions of section 162 of the Internal Revenue Code of 1954. The pertinent provisions of this section are set forth in the margin.1

Petitioner’s principal argument in support of the deduction is that research and writing are a part of being a professor at a liberal arts college and that his trip and work in England were a natural outgrowth of this occupation. In…

2Cases cited7 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. HeiningerSupreme Court of the United States · 1943
  3. Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
  4. Hill v. CommissionerUnited States Tax Court · 1949
  5. Cardozo v. CommissionerUnited States Tax Court · 1951

2 more not listed; retrieve them via the Exa API.

3Cited by12 opinions

  1. Bodzin v. CommissionerUnited States Tax Court · 1973
  2. Simenon v. CommissionerUnited States Tax Court · 1965
  3. Fogg v. CommissionerUnited States Tax Court · 1987
  4. Dietrich v. CommissionerUnited States Tax Court · 1971
  5. Bodzin v. CommissionerUnited States Tax Court · 1973

7 more not listed; retrieve them via the Exa API.

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