Legal Opinion

Allison v. Commissioner

United States Tax Court

Decided August 22, 1977No. Docket No. 9238-75Unpublished

Petitioners, husband and wife, were employed as high school teachers. In the summer of 1972 they toured Europe for 54 days. Held, petitioners have failed to establish that the major portion of the activities during their European trip was of a nature directly related to their respective teaching duties and which directly maintained or improved skills required of them in their respective employment.

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Petitioners, husband and wife, were employed as high school teachers. In the summer of 1972 they toured Europe for 54 days. Held, petitioners have failed to establish that the major portion of the activities during their European trip was of a nature directly related to their respective teaching duties and which directly maintained or improved skills required of them in their respective employment. Accordingly their travel expenses are not deductible as ordinary and necessary business expenses.

1Opinion of the Court

KENNETH W. ALLISON AND ERMA L. ALLISON, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Allison v. Commissioner

Docket No. 9238-75.

United States Tax Court

T.C. Memo 1977-277; 1977 Tax Ct. Memo LEXIS 160; 36 T.C.M. (CCH) 1114; T.C.M. (RIA) 770277;

August 22, 1977, Filed

Petitioners, husband and wife, were employed as high school teachers. In the summer of 1972 they toured Europe for 54 days. Held, petitioners have failed to establish that the major portion of the activities during their European trip was of a nature directly related to their respective teaching duties and which…

2Cases cited2 opinions

  1. Marlin v. CommissionerUnited States Tax Court · 1970
  2. Edwin F. Krist and Marion R. Krist v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973

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