Taubman v. Commissioner
United States Tax Court
Petitioner, an accountant, entered law school in 1966, and received his bachelor of laws degree in 1969. Held, such school expenses are nondeductible because they were incurred in the pursuit of a program of study "which will lead him to qualifying in a new trade or business," sec. 1.162-5(b)(3), Income Tax Regs., namely the practice of law.
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Petitioner, an accountant, entered law school in 1966, and received his bachelor of laws degree in 1969. Held, such school expenses are nondeductible because they were incurred in the pursuit of a program of study "which will lead him to qualifying in a new trade or business," sec. 1.162-5(b)(3), Income Tax Regs., namely the practice of law. Held, further: That we will not consider in the instant case petitioner's equal protection attack on the aforementioned regulation to the effect that such regulation unconstitutionally favors teachers over other professionals. This argument was not…
1Opinion of the Court
Forrester, Judge:
Respondent has determined a deficiency of $161 in petitioners’ income tax for the calendar year 1969. The sole issue for our decision is whether petitioners are entitled, under section 162(a),1 to a deduction of $764 for expenses incurred in pursuit of a legal education. If we decide for respondent on this issue, it is not . in dispute that we will then disallow $12 of the $522 medical expense deduction claimed by petitioners.
FINDINGS OF FACT
Some of the facts were stipulated and are so found.
Petitioners Morton S. Taubman and llene P. Taubman are husband and wife, who, at the…
2Cases cited18 opinions
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
- Helvering v. ReynoldsSupreme Court of the United States · 1941
- Weiszmann v. CommissionerUnited States Tax Court · 1969
- Ronald F. Weiszmann and Deborah C. Weiszmann v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- White v. Winchester Country ClubSupreme Court of the United States · 1942
13 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Feistman v. CommissionerUnited States Tax Court · 1974
- Glenn v. CommissionerUnited States Tax Court · 1974
- O'Donnell v. CommissionerUnited States Tax Court · 1974
- Latham Park Manor, Inc. v. CommissionerUnited States Tax Court · 1977
- Diaz v. CommissionerUnited States Tax Court · 1978
26 more not listed; retrieve them via the Exa API.