Legal Opinion

Jungreis v. Commissioner

United States Tax Court

Decided December 24, 1970No. Docket No. 6218-69PublishedCited by 41 opinions

In 1967 petitioner was employed by the University of Minnesota on a part-time basis as a graduate teaching assistant in the zoology department. Since he then had only a bachelor of science degree, he was not qualified for the position of a regular full-time faculty member at the university.

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In 1967 petitioner was employed by the University of Minnesota on a part-time basis as a graduate teaching assistant in the zoology department. Since he then had only a bachelor of science degree, he was not qualified for the position of a regular full-time faculty member at the university. He was enrolled as a student in the graduate school and was a candidate for a doctor of philosophy degree in zoology which was required to qualify him as a regular full-time faculty member. The university required petitioner to be enrolled as a graduate student before he could be eligible for an…

1Opinion of the Court

OPINION

Dawson Judge:

Respondent determined a deficiency of $65.24 in petitioner’s Federal income tax for the year 1967.

Petitioner has conceded two adjustments made by respondent. The only issue presented for decision is whether the petitioner is entitled to deduct under section 162(a), I.R.C. 1954,2 and section 1.162-5, Income Tax Regs., as amended in T.D. 6918, 1967-1 C.B. 36, expenses incurred in taking graduate courses while serving as a graduate teaching assistant during 1967 at the University of Minnesota.3

All of the facts have been stipulated. The stipulation of facts and supplemental…

2Cases cited9 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Weiszmann v. CommissionerUnited States Tax Court · 1969
  3. Carroll v. CommissionerUnited States Tax Court · 1968
  4. James A. And Isabelle Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
  5. Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950

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

3Cited by41 opinions

  1. Davis v. CommissionerUnited States Tax Court · 1976
  2. Ford v. CommissionerUnited States Tax Court · 1971
  3. Diaz v. CommissionerUnited States Tax Court · 1978
  4. Wassenaar v. CommissionerUnited States Tax Court · 1979
  5. Garwood v. CommissionerUnited States Tax Court · 1974

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

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