Legal Opinion

Garwood v. Commissioner

United States Tax Court

Decided August 28, 1974No. Docket No. 2530-73PublishedCited by 16 opinions

Held, the expenses incurred by a substitute teacher to obtain a bachelor of arts degree are not deductible as ordinary and necessary business expenses under sec. 162, I.R.C. 1954.

1Opinion of the Court

Simpson, Judge:

The respondent determined a deficiency of $254 in the Federal income tax of the petitioner for the year 1970. The only issue for decision is whether the expenses incurred by a substitute teacher in obtaining a bachelor of arts degree are deductible under section 162 of the Internal Revenue Code of 19541 as ordinary and necessary business expenses.

FINDINGS OF FACT

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

The petitioner, Ronald E. Garwood, was a resident of Detroit, Mich., at the time his petition was filed in this case. He filed an individual Federal…

2Cases cited10 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. James A. And Isabelle Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
  4. Bodley v. CommissionerUnited States Tax Court · 1971
  5. Weiler v. CommissionerUnited States Tax Court · 1970

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

3Cited by16 opinions

  1. Diaz v. CommissionerUnited States Tax Court · 1978
  2. Toner v. CommissionerUnited States Tax Court · 1979
  3. Barboza v. CommissionerUnited States Tax Court · 1991
  4. Cohn v. CommissionerUnited States Tax Court · 1985
  5. Damm v. CommissionerUnited States Tax Court · 1981

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

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