Legal Opinion
United States v. Howard K. Michaelsen and Fayetta M. Michaelsen, Commissioner of Internal Revenue v. Elmer R. Johnson and Bernice E. Johnson
Court of Appeals for the Ninth Circuit
Decided January 31, 1963No. 17898_1PublishedCited by 18 opinions
1Opinion of the Court
MERRILL, Circuit Judge.
In these two cases the same question is presented: whether a teacher-taxpayer may deduct as ordinary and necessary expenses of business the cost of education secured in order to permit him to> continue in the teaching profession. While the cases present different aspects of the problem, the same sections of code and regulations are involved and for clarity of discussion it has been thought, best to consolidate the two cases in one opinion.
The deductions are sought under § 162 (a) of the Internal Revenue Code of 1954, which provides:
“There shall be allowed as a deduction…
2Cases cited4 opinions
- Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- Marlor v. CommissionerUnited States Tax Court · 1956
- Green v. CommissionerUnited States Tax Court · 1957
- Clark S. Marlor v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
3Cited by18 opinions
- Jungreis v. CommissionerUnited States Tax Court · 1970
- Toner v. CommissionerUnited States Tax Court · 1979
- Charlton v. CommissionerUnited States Tax Court · 1964
- Louis H. Rombach and Ann M. Rombach v. The United StatesUnited States Court of Claims · 1971
- Williams v. United StatesDistrict Court, S.D. New York · 1965
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