Legal Opinion

Horodysky v. Commissioner

United States Tax Court

Decided March 16, 1970No. Docket No. 902-68Published

Petitioner migrated from Europe to Ohio in 1948, having previously been a lawyer in Poland, his former country. Petitioner was not able to practice law in Ohio, having been advised that he must graduate from law school before being admitted to the bar. In 1963, petitioner enrolled in law school and in 1967, he completed law school and passed Ohio's bar examination. Shortly thereafter, he obtained full-time employment as a practicing lawyer.

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Petitioner migrated from Europe to Ohio in 1948, having previously been a lawyer in Poland, his former country. Petitioner was not able to practice law in Ohio, having been advised that he must graduate from law school before being admitted to the bar. In 1963, petitioner enrolled in law school and in 1967, he completed law school and passed Ohio's bar examination. Shortly thereafter, he obtained full-time employment as a practicing lawyer. Held, petitioner's expenses for attending law school do not qualify within the meaning of sec. 1.162-5(a)(2), Income Tax Regs., as a deductible…

1Opinion of the Court

Yaroslaw Horodysky and Stephanie Horodysky, Petitioners v. Commissioner of Internal Revenue, Respondent

Horodysky v. Commissioner

Docket No. 902-68

United States Tax Court

54 T.C. 490; 1970 U.S. Tax Ct. LEXIS 191;

March 16, 1970, Filed

Decision will be entered for the respondent.

Petitioner migrated from Europe to Ohio in 1948, having previously been a lawyer in Poland, his former country. Petitioner was not able to practice law in Ohio, having been advised that he must graduate from law school before being admitted to the bar. In 1963, petitioner enrolled in law school and in 1967, he completed law…

2Cases cited6 opinions

  1. Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
  2. Baker v. CommissionerUnited States Tax Court · 1968
  3. Denman v. CommissionerUnited States Tax Court · 1967
  4. Hill v. CommissionerUnited States Tax Court · 1949
  5. Ryman v. CommissionerUnited States Tax Court · 1969

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