Legal Opinion

Carroll v. Commissioner

United States Tax Court

Decided October 31, 1968No. Docket No. 3722-66PublishedCited by 110 opinions

Petitioner, while employed as a policeman, undertook a general college education as a philosophy major. Held, amounts spent for such education are personal expenses not deductible from gross income as ordinary and necessary expenses of carrying on a trade or business.

1Opinion of the Court

Simpson, Judge:

Respondent determined a deficiency in petitioners’ 1964 income tax in the amount of $207.17. The issue for decision in this case is whether the petitioner, James A. Carroll, is entitled to deduct certain educational expenses.

FINDINGS OP PACT

Some of the facts have been stipulated, and those facts are so¡ found.

Petitioners, James A. and Isabelle Carroll, are husband and wife, ■who resided in Chicago, Ill., at the time the petition was filed in this case. They filed their 1964 joint Federal income tax return, using the cash receipts and disbursements method of accounting, with the…

2Cases cited8 opinions

  1. Kornhauser v. United StatesSupreme Court of the United States · 1928
  2. Kroll v. CommissionerUnited States Tax Court · 1968
  3. Yeomans v. CommissionerUnited States Tax Court · 1958
  4. Henry v. CommissionerUnited States Tax Court · 1961
  5. Carlucci v. CommissionerUnited States Tax Court · 1962

3 more not listed; retrieve them via the Exa API.

3Cited by110 opinions

  1. Sharon v. CommissionerUnited States Tax Court · 1976
  2. Weiszmann v. CommissionerUnited States Tax Court · 1969
  3. Bodley v. CommissionerUnited States Tax Court · 1971
  4. Boser v. CommissionerUnited States Tax Court · 1981
  5. Marlin v. CommissionerUnited States Tax Court · 1970

105 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API