Davis v. Commissioner
United States Tax Court
Before her enrollment as a full-time graduate student in a Ph.D. program in social work, P held various positions in social work involving the performance of casework, teaching, and research. The Ph.D. program was primarily designed for teaching and research in social work, and members of the faculty of that school are ordinarily required to have a Ph.D. degree.
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Before her enrollment as a full-time graduate student in a Ph.D. program in social work, P held various positions in social work involving the performance of casework, teaching, and research. The Ph.D. program was primarily designed for teaching and research in social work, and members of the faculty of that school are ordinarily required to have a Ph.D. degree. After she obtained such degree, she secured a full-time faculty position at that school. 1. Held, since the Ph.D. degree obtained by P was the minimum amount of education normally required for the employment she secured as a full-time…
1Opinion of the Court
OPINION
Simpson, Judge:
The Commissioner determined a deficiency of $588:05 in the petitioners’ Federal income tax for 1969. One issue has been conceded by the petitioners, and the only issue remaining for decision is whether the petitioner, Inger P. Davis, may deduct expenditures for tuition and books as business expenses under section 162(a) of the Internal Revenue Code of 1954.1
All of the facts have been stipulated, and those facts are so found.
The petitioners, Kenneth C. Davis and Inger P. Davis, husband and wife, resided in Chicago, Ill., when they filed their petition herein. They filed a…
2Cases cited36 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Atchison, Topeka & Santa Fe Railway Co. v. Wichita Board of TradeSupreme Court of the United States · 1973
- Greater Boston Television Corp. v. Federal Communications CommissionCourt of Appeals for the D.C. Circuit · 1970
- Dixon v. United StatesSupreme Court of the United States · 1965
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
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3Cited by127 opinions
- Sharon v. CommissionerUnited States Tax Court · 1976
- Joel A. Sharon and Ann L. Sharon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Malinowski v. CommissionerUnited States Tax Court · 1979
- Vons Companies, Inc. v. United StatesUnited States Court of Federal Claims · 2001
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