Legal Opinion

Denman v. Commissioner

United States Tax Court

Decided June 26, 1967No. Docket Nos. 3515-62, 3955-62Published

1. In reporting his taxable income for the taxable years herein petitioner capitalized the total estimated cost of his college or higher education as the basis to him of his engineering degree and based on an assumed life therefor until he reached age 65, deducted $ 694 as depreciation on each of his returns for the years in question.

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1. In reporting his taxable income for the taxable years herein petitioner capitalized the total estimated cost of his college or higher education as the basis to him of his engineering degree and based on an assumed life therefor until he reached age 65, deducted $ 694 as depreciation on each of his returns for the years in question. Held, that petitioner has not brought the amount so claimed within the ambit of sec. 167, I.R.C. 1954. 2. During the taxable years herein petitioner carried on personal business activities under the name Basic & Experimental Physics. Generally these activities…

1Opinion of the Court

Nathaniel A. Denman and Lucille G. Denman, Petitioners v. Commissioner of Internal Revenue, Respondent; Nathaniel A. Denman, Petitioner v. Commissioner of Internal Revenue, Respondent

Denman v. Commissioner

Docket Nos. 3515-62, 3955-62

United States Tax Court

48 T.C. 439; 1967 U.S. Tax Ct. LEXIS 82;

June 26, 1967, Filed

Decisions will be entered under Rule 50.

1. In reporting his taxable income for the taxable years herein petitioner capitalized the total estimated cost of his college or higher education as the basis to him of his engineering degree and based on an assumed life therefor until he…

2Cases cited14 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Commissioner v. FlowersSupreme Court of the United States · 1946
  4. Commissioner v. TellierSupreme Court of the United States · 1966
  5. Avery v. CommissionerSupreme Court of the United States · 1934

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