Love Box Company, Inc. v. Commissioner of Internal Revenue

I agree with the majority that this case involves review of a mixed question of law and fact, whether educational seminar expenses of the taxpayer are deductible as ordinary and necessary business expenses pursuant to I.R.C. § 162. See Rev.Rul. 76-71, 1976-1 C.B. 808, 810 (educational expenses incurred by employer for employees are deductible as ordinary and necessary business expenses if test of Treas. Reg. § 1.162-5 met). There appears to be no disagreement that the subjects taught at the seminars, economic history, comparative economics and philosophy, were valuable to the participants.…