Linda M. Liberi Toner v. Commissioner of Internal Revenue

OPINION OF THE COURT

SEITZ, Chief Judge.

Linda M. Liberi Toner (the taxpayer) appeals a final decision of the Tax Court that determined a deficiency of $177.41 against her for deductions relating to her educational expenses.

I

In 1971, taxpayer became a teacher at St. Clement’s, a parochial school in the Archdiocese of Philadelphia. She taught both religious and secular subjects to fifth grade students. At the time of her initial employment, the taxpayer had graduated from high school and had completed two years of a four-year college degree program.

At all relevant times the Archdiocese has only…