Legal Opinion
Ramon M. Greenberg v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided October 25, 1966No. 6751_1PublishedCited by 16 opinions
1Opinion of the Court
COFFIN, Circuit Judge.
The sole question in this case is whether the Tax Court erred in denying a deduction claimed by petitioner, a psychiatrist, as an “ordinary and necessary” business expense, for the cost of his own analysis as part of an extensive training program in psychoanalysis.
The availability of the deduction claimed under 26 U.S.C. § 162(a) depends upon the pertinent 1954 Treasury Regulations, which are set forth in the margin. 1 The critical question raised by these regulations is whether petitioner’s psychoanalytic studies, including his own analysis, were undertaken to improve…
2Cases cited15 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Carlucci v. CommissionerUnited States Tax Court · 1962
- 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
10 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Nathan Fleischer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1968
- Evelyn R. Marks v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
- Voigt v. CommissionerUnited States Tax Court · 1980
- Burnstein v. CommissionerUnited States Tax Court · 1976
- Baker v. CommissionerUnited States Tax Court · 1968
11 more not listed; retrieve them via the Exa API.