Carlucci v. Commissioner
United States Tax Court
The petitioner, a qualified industrial psychologist, was employed as such by an insurance company in Newark, New Jersey, and resided in such city. During 1958 he continued to take evening courses in the general field of industrial psychology at New York University, located in New York City. He attended 42 classes and incurred costs of tuition, textbooks and supplies, meals, and transportation to and from New York.
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The petitioner, a qualified industrial psychologist, was employed as such by an insurance company in Newark, New Jersey, and resided in such city. During 1958 he continued to take evening courses in the general field of industrial psychology at New York University, located in New York City. He attended 42 classes and incurred costs of tuition, textbooks and supplies, meals, and transportation to and from New York. Held, that the education was undertaken primarily for the purpose of maintaining or improving the petitioner's skill (as an industrial psychologist) required by him in his…
1Opinion of the Court
Atkins, Judge:
The respondent determined a deficiency in income tax in the amount of $490.30 for the taxable year 1958. The petitioner having conceded that the respondent correctly disallowed a claimed deduction for dependents, the only issue for decision is whether the petitioner is entitled to deduct, as ordinary and necessary business expenses under section 162 of the Internal Revenue Code of 1954, amounts paid for tuition and other costs of attending university classes. ■
FINDINGS OF FACT.
Some of the facts are stipulated and are incorporated herein by this reference.
The petitioner is a…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Watson v. CommissionerUnited States Tax Court · 1959
- 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
- Namrow v. CommissionerUnited States Tax Court · 1959
- Booth v. CommissionerUnited States Tax Court · 1961
1 more not listed; retrieve them via the Exa API.
3Cited by78 opinions
- Carroll v. CommissionerUnited States Tax Court · 1968
- James A. And Isabelle Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
- Zimmerman v. CommissionerUnited States Tax Court · 1978
- Boser v. CommissionerUnited States Tax Court · 1981
- Ford v. CommissionerUnited States Tax Court · 1971
73 more not listed; retrieve them via the Exa API.