Brown v. Commissioner
United States Tax Court
In order to provide a better education for her son in a safer environment, and in order to free herself to seek and hold gainful employment, petitioner enrolled her 13-year old son in boarding school. She considered herself unable to work while her son remained in public school due to constantly arising problems (teacher strikes, classroom disorders, and gang fights) at the public school.
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In order to provide a better education for her son in a safer environment, and in order to free herself to seek and hold gainful employment, petitioner enrolled her 13-year old son in boarding school. She considered herself unable to work while her son remained in public school due to constantly arising problems (teacher strikes, classroom disorders, and gang fights) at the public school. Held, such portion of the boarding school costs as is allocable to child care rather than to education was deductible for 1974 and 1975 under sec. 214(b)(2), I.R.C. 1954, as expenses for child care incurred…
1Opinion of the Court
Hall, Judge:
Respondent determined deficiencies in petitioner’s income tax of $493.07 for 1974 and $306.77 for 1975. The sole issue for decision is whether petitioner is entitled to deduct any of the costs of sending her son to military school as child care expenses.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
At the time of filing her petition, petitioner was a resident of Philadelphia, Pa.
Prior to 1972, petitioner resided with her son Albert in Montgomery County, Md. During this period, petitioner was employed by the Federal Government. In 1972, petitioner…
2Cited by5 opinions
- Zoltan v. CommissionerUnited States Tax Court · 1982
- Ahlstrand v. CommissionerUnited States Tax Court · 1980
- Babilonia v. CommissionerUnited States Tax Court · 1980
- Brown v. CommissionerUnited States Tax Court · 1979
- Zoltan v. CommissionerUnited States Tax Court · 1982