Legal Opinion

Wyatt v. Commissioner

United States Tax Court

Decided June 16, 1971No. Docket No. 312-70 SCPublishedCited by 14 opinions

From the summer of 1963 through July 1967, petitioner was employed as a secretary. Prior to such employment, she taught secretarial skills at the secondary school level. From February through August 1967, petitioner incurred expenses in taking graduate education courses to prepare for resuming employment as a teacher.

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From the summer of 1963 through July 1967, petitioner was employed as a secretary. Prior to such employment, she taught secretarial skills at the secondary school level. From February through August 1967, petitioner incurred expenses in taking graduate education courses to prepare for resuming employment as a teacher. She began teaching in late August 1967. Held: At the time petitioner incurred her education expenses, she was not engaged in the trade or business of being a teacher. Such expenses were incurred in preparation for resuming such occupation and accordingly are not deductible under…

1Opinion of the Court

Foreester, Judge:

Respondent has determined a deficiency in petitioners’ joint Federal income tax for 1967 in the amount of $77.22.

The only issue for decision is whether LaRue Wyatt is entitled to a deduction for educational expenses incurred in 1967.

ETNDINCS OE FACT

Some of the facts have been stipulated. The stipulations and exhibits attached thereto are incorporated herein by this reference.

Petitioners herein are Don E. Wyatt and his wife, LaRue Wyatt (hereinafter sometimes referred to as LaRue), who both resided in Overland Park, Kans., at the time their petition in the instant case was…

2Cases cited5 opinions

  1. Fischer v. CommissionerUnited States Tax Court · 1968
  2. Owen v. CommissionerUnited States Tax Court · 1954
  3. Mary O. Furner v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1968
  4. Furner v. Comm'rUnited States Tax Court · 1966
  5. Corbett v. CommissionerUnited States Tax Court · 1971

3Cited by14 opinions

  1. Gallery v. CommissionerUnited States Tax Court · 1971
  2. Picknally v. CommissionerUnited States Tax Court · 1977
  3. Baist v. CommissionerUnited States Tax Court · 1988
  4. Beard v. CommissionerUnited States Tax Court · 1995
  5. Carter v. CommissionerUnited States Tax Court · 1978

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