Cardozo v. Commissioner
United States Tax Court
Petitioner, a professor at The Catholic University of America, in the Summer of 1947 undertook a European trip for study and research. The trip was made voluntarily, at petitioner's expense, for the purpose of increasing his prestige, to improve his reputation for scholarship and learning, and to better fit him for the duties he was employed to perform.
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Petitioner, a professor at The Catholic University of America, in the Summer of 1947 undertook a European trip for study and research. The trip was made voluntarily, at petitioner's expense, for the purpose of increasing his prestige, to improve his reputation for scholarship and learning, and to better fit him for the duties he was employed to perform. Petitioner claims a deduction of the amounts expended for travel and maintenance as ordinary and necessary expenses incurred in carrying on his profession. Held: Such expenditures were of a personal nature and, therefore, under section 24 (a)…
1Opinion of the Court
OPINION.
Leech, Judge:
The sole question presented is whether petitioner is entitled to a deduction of the amount of $1,144, representing expenditures incurred in the taxable year in connection with a European trip, as ordinary and necessary expenses within the purview of sections 23 (a) (1) (A) or 23 (a) (2) of the Internal Revenue Code, or whether they constitute personal expenses nondeductible under section 24 (a) (1). The pertinent provisions of these sections are set forth in the margin.1 The. amount involved is not in dispute.
Petitioner contends that the expenditures involved were…
2Cases cited4 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- Hill v. CommissionerUnited States Tax Court · 1949
3Cited by23 opinions
- Heineman v. CommissionerUnited States Tax Court · 1984
- Arnold Namrow and Lillian Namrow, and Jay C. Maxwell and Dorothy N. Maxwell v. Commissioner of Internal RevnueCourt of Appeals for the Fourth Circuit · 1961
- Marlor v. CommissionerUnited States Tax Court · 1956
- Matilda M. Brooks v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Kamins v. CommissionerUnited States Tax Court · 1956
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