Legal Opinion

Glenn v. Commissioner

United States Tax Court

Decided May 30, 1974No. Docket No. 1110-73PublishedCited by 75 opinions

Petitioner is a licensed public accountant in Tennessee. In 1970, in preparation for the exam required to be taken by all candidates for C.P.A. licenses in Tennessee, petitioner attended a review course at the University of Alabama. On his return, he claimed deductions for the cost of the course, as well as for the expenses he incurred in taking the exam.

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Petitioner is a licensed public accountant in Tennessee. In 1970, in preparation for the exam required to be taken by all candidates for C.P.A. licenses in Tennessee, petitioner attended a review course at the University of Alabama. On his return, he claimed deductions for the cost of the course, as well as for the expenses he incurred in taking the exam. Held, that the review course constituted "education" within the meaning and purview of sec. 1.162-5, Income Tax Regs.Held, further, because there are significant differences between the potential practice of a public accountant and that of a…

1Opinion of the Court

FORRESTER, Judge:

Respondent has determined a deficiency of $225.36 in petitioner’s 1970 Federal income taxes. The sole issue for our decision is whether or not petitioner may deduct expenses he incurred in taking a review course and in sitting for the C.P.A. exam in Tennessee.

FINDINGS OF FACT

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

William D. Glenn, petitioner, was a resident of Nashville, Tenn., at the time he filed the petition herein. He filed his 1970 calendar year Federal income tax return with the director, Internal Revenue Service Center, Chamblee, Ga.

Petitioner received…

2Cases cited7 opinions

  1. Weiszmann v. CommissionerUnited States Tax Court · 1969
  2. Ronald F. Weiszmann and Deborah C. Weiszmann v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
  3. Weiler v. CommissionerUnited States Tax Court · 1970
  4. Taubman v. CommissionerUnited States Tax Court · 1973
  5. Ryman v. CommissionerUnited States Tax Court · 1969

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

3Cited by75 opinions

  1. Sharon v. CommissionerUnited States Tax Court · 1976
  2. Davis v. CommissionerUnited States Tax Court · 1976
  3. Joel A. Sharon and Ann L. Sharon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
  4. O'Donnell v. CommissionerUnited States Tax Court · 1974
  5. Browne v. CommissionerUnited States Tax Court · 1980

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

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