Denman v. Commissioner
United States Tax Court
1. In reporting his taxable income for the taxable years herein petitioner capitalized the total estimated cost of his college or higher education as the basis to him of his engineering degree and based on an assumed life therefor until he reached age 65, deducted $ 694 as depreciation on each of his returns for the years in question.
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1. In reporting his taxable income for the taxable years herein petitioner capitalized the total estimated cost of his college or higher education as the basis to him of his engineering degree and based on an assumed life therefor until he reached age 65, deducted $ 694 as depreciation on each of his returns for the years in question. Held, that petitioner has not brought the amount so claimed within the ambit of sec. 167, I.R.C. 1954. 2. During the taxable years herein petitioner carried on personal business activities under the name Basic & Experimental Physics. Generally these activities…
1Opinion of the Court
TURNER, Judge:
Despondent determined deficiencies in income tax against petitioners as follows:
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The issues for decision are as follows: (1) Whether Nathaniel A. Denman, sometimes hereinafter referred to as petitioner, is entitled to deduct in each of the taxable years a prorata part of the cost of his college or higher education as an allowance for depreciation of his engineering degree; (2) whether for the taxable years 1956 and 1957 he is entitled to deduct his lodging and living costs incurred by him at his places of employment; (3) whether he is entitled to deduct as an…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Commissioner v. TellierSupreme Court of the United States · 1966
- Avery v. CommissionerSupreme Court of the United States · 1934
8 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Sharon v. CommissionerUnited States Tax Court · 1976
- Bodley v. CommissionerUnited States Tax Court · 1971
- Eller v. CommissionerUnited States Tax Court · 1981
- Horodysky v. CommissionerUnited States Tax Court · 1970
- Jenkins v. CommissionerUnited States Tax Court · 1988
26 more not listed; retrieve them via the Exa API.