Legal Opinion

Takahashi v. Commissioner

United States Tax Court

Decided July 21, 1986No. Docket No. 10640-83PublishedCited by 5 opinions

On their 1981 Federal income tax return Ps, high school science teachers, claimed, as education expenses under sec. 162(a), I.R.C. 1954, certain expenses which they incurred to attend a cultural seminar in Hawaii. Also, on their 1979, 1980, and 1981 returns, Ps claimed losses in connection with the operation of a farm.

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On their 1981 Federal income tax return Ps, high school science teachers, claimed, as education expenses under sec. 162(a), I.R.C. 1954, certain expenses which they incurred to attend a cultural seminar in Hawaii. Also, on their 1979, 1980, and 1981 returns, Ps claimed losses in connection with the operation of a farm. Held, a course providing general cultural enrichment is not sufficiently germane to the teaching of science to bring the course within the category of a "refresher," "current developments," or "academic or vocational" course as required by regulations to qualify the course for…

1Opinion of the Court

NlMS, Judge:

Respondent determined deficiencies in and additions to petitioners’ Federal income taxes as follows:

Additions to tax

Year Deficiency sec. 6653(a)1

1979 $1,536

1980 1,389 $69.45

1981 2,686 134.30

After concessions, the issues for decision are: (1) Whether petitioners are entitled to deduct certain expenses which they incurred to attend a seminar in Hawaii as education expenses under section 162(a); (2) whether the operation of petitioner’s farm was an activity “not engaged in for profit” within the meaning of section 183; and (3) whether petitioners are Hable for additions to tax for…

2Cases cited9 opinions

  1. Dreicer v. CommissionerUnited States Tax Court · 1982
  2. Golanty v. CommissionerUnited States Tax Court · 1979
  3. Fox v. CommissionerUnited States Tax Court · 1983
  4. John W. Barnard & June W. Barnard, Earl D. Kay, Jr. & Nancy O. Kay, Joseph J. Allen & Jennene S. Allen v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1984
  5. Lemmen v. CommissionerUnited States Tax Court · 1981

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

3Cited by5 opinions

  1. Joseph v. Comm'rUnited States Tax Court · 2005
  2. Del Guercio v. CommissionerUnited States Tax Court · 1989
  3. Dunkel v. CommissionerUnited States Tax Court · 1991
  4. Lockwood v. CommissionerUnited States Tax Court · 1989
  5. Takahashi v. CommissionerUnited States Tax Court · 1986

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