Ashby H. Canter and Florence G. Canter v. The United States

COLLINS, Judge.

During 1960, Florence G. Canter, one of the joint petitioners, was a full-time student of nursing at the University of Maryland. In their 1960 Federal income tax return, petitioners treated as a deduction expenses related to Mrs. Canter’s education. (Hereafter, the term “plaintiff” will refer to Florence G. Canter.) The deduction was disallowed by the Internal Revenue Service, and the present suit followed.

Section 162 of the Internal Revenue Code of 1954 states, in part, that: “There shall be allowed as a deduction all *353the ordinary and necessary expenses paid or incurred during…