Takahashi v. Commissioner
United States Tax Court
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
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Golanty v. CommissionerUnited States Tax Court · 1979
- Fox v. CommissionerUnited States Tax Court · 1983
- 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
- Lemmen v. CommissionerUnited States Tax Court · 1981
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Joseph v. Comm'rUnited States Tax Court · 2005
- Del Guercio v. CommissionerUnited States Tax Court · 1989
- Dunkel v. CommissionerUnited States Tax Court · 1991
- Lockwood v. CommissionerUnited States Tax Court · 1989
- Takahashi v. CommissionerUnited States Tax Court · 1986