Legal Opinion

Bakken v. Commissioner

United States Tax Court

Decided January 13, 1969No. Docket Nos. 2327-67, 715-68Published

Petitioner, while employed as a full-time engineer at the Sandia Corp., enrolled in an evening law school course of study leading to the degree of juris doctor. His subjective purpose in studying law was to develop the abilities of logical reasoning and self-expression, the development of which was necessary if petitioner was to maintain his job status at Sandia.

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Petitioner, while employed as a full-time engineer at the Sandia Corp., enrolled in an evening law school course of study leading to the degree of juris doctor. His subjective purpose in studying law was to develop the abilities of logical reasoning and self-expression, the development of which was necessary if petitioner was to maintain his job status at Sandia. Held, the expenditures for the education are not deductible under sec. 162(a), I.R.C. 1954, as the education was not directly and proximately related to petitioner's employment; the expenditures were not for education undertaken…

1Opinion of the Court

Lawrence H. Bakken, Petitioner v. Commissioner of Internal Revenue, Respondent

Bakken v. Commissioner

Docket Nos. 2327-67, 715-68

United States Tax Court

51 T.C. 603; 1969 U.S. Tax Ct. LEXIS 211;

January 13, 1969, Filed

Decisions will be entered for the Commissioner.

Petitioner, while employed as a full-time engineer at the Sandia Corp., enrolled in an evening law school course of study leading to the degree of juris doctor. His subjective purpose in studying law was to develop the abilities of logical reasoning and self-expression, the development of which was necessary if petitioner was to…

2Cases cited4 opinions

  1. Kornhauser v. United StatesSupreme Court of the United States · 1928
  2. Carroll v. CommissionerUnited States Tax Court · 1968
  3. Henry v. CommissionerUnited States Tax Court · 1961
  4. Bakken v. CommissionerUnited States Tax Court · 1969

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