Porter v. Commissioner
United States Tax Court
During 1979 and 1980, P, a practicing psychiatrist, underwent psychotherapy. P deducted the costs he incurred in undergoing psychotherapy as ordinary and necessary business expenses under section 162(a), I.R.C. 1954. Held, because the psychotherapy improved P's skills as a psychiatrist, he is entitled to deduct the expenses he incurred in undergoing psychotherapy as an education expense under section 162(a), I.R.C. 1954. Iglesias v. Commissioner,76 T.C. 1060 (1981), and…
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During 1979 and 1980, P, a practicing psychiatrist, underwent psychotherapy. P deducted the costs he incurred in undergoing psychotherapy as ordinary and necessary business expenses under section 162(a), I.R.C. 1954. Held, because the psychotherapy improved P's skills as a psychiatrist, he is entitled to deduct the expenses he incurred in undergoing psychotherapy as an education expense under section 162(a), I.R.C. 1954. Iglesias v. Commissioner,76 T.C. 1060 (1981), and Voigt v. Commissioner,74 T.C. 82 (1980), applied. Held further, the amount of deductible telephone expenses under section…
1Opinion of the Court
KENNETH PORTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Porter v. Commissioner
Docket Nos. 19074-83, 36261-84.
United States Tax Court
T.C. Memo 1986-70; 1986 Tax Ct. Memo LEXIS 539; 51 T.C.M. (CCH) 477; T.C.M. (RIA) 86070;
February 13, 1986.
During 1979 and 1980, P, a practicing psychiatrist, underwent psychotherapy. P deducted the costs he incurred in undergoing psychotherapy as ordinary and necessary business expenses under section 162(a), I.R.C. 1954. Held, because the psychotherapy improved P's skills as a psychiatrist, he is entitled to deduct the expenses he incurred in…
2Cases cited13 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Stephenson v. CommissionerUnited States Tax Court · 1982
- John L. Stephenson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
- Professional Services v. CommissionerUnited States Tax Court · 1982
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