Lund v. Commissioner
United States Tax Court
Petitioners, flight engineers on propeller aircraft, took pilot training in order to meet the requirement of their employer that the second officer who performed the flight engineer's functions on jet aircraft hold a commercial pilot's license and instrument rating.
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Petitioners, flight engineers on propeller aircraft, took pilot training in order to meet the requirement of their employer that the second officer who performed the flight engineer's functions on jet aircraft hold a commercial pilot's license and instrument rating. Held, petitioners are entitled to deduct the expenditures made for training to acquire commercial pilots' licenses and instrument ratings since this training improved their skill as flight engineers and met a specific requirement of their employer for the retention of their status as flight crew members doing the flight engineer's…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioners’ income taxes as follows:
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All issues raised by the pleadings in all the cases have been disposed of by agreement of the parties except the issues relating to deductions for educational expenses claimed by one of petitioners in each case for each, year involved therein under section 162(a) of the Internal Revenue Code of 1954.
The issue for decision is whether amounts expended by flight engineers employed by a commercial airline for training to qualify for commercial pilot’s licenses and instrument ratings are…
2Cases cited12 opinions
- Carlucci v. CommissionerUnited States Tax Court · 1962
- Watson v. CommissionerUnited States Tax Court · 1959
- Booth v. CommissionerUnited States Tax Court · 1961
- Martin J. Welsh and Elsie N. Welsh v. United StatesCourt of Appeals for the Sixth Circuit · 1964
- Sandt v. CommissionerCourt of Appeals for the Third Circuit · 1962
7 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Boser v. CommissionerUnited States Tax Court · 1981
- Mason v. CommissionerUnited States Tax Court · 1982
- Boser v. CommissionerUnited States Tax Court · 1981
- Brandt v. CommissionerUnited States Tax Court · 1982
- Galbreath v. CommissionerUnited States Tax Court · 1982
9 more not listed; retrieve them via the Exa API.