Reisinger v. Commissioner
United States Tax Court
Held, petitioner-wife was not engaged in 1975 in the trade or business of being a licensed practical nurse having been unemployed since 1969. Held, further, the education expenses of petitioner-wife at the Johns Hopkins Health Associates Program from Sept. 3, 1974, through the spring of 1976 qualified her for the new trade or business of physician's assistant and are therefore nondeductible.
1Opinion of the Court
Dawson, Judge:
Respondent determined a deficiency of $610.74 in petitioners’ Federal income tax for the year 1975.
Concessions having been made by the parties, the only issue presented for decision is whether petitioner Patricia K. Reisinger, a qualified licensed practical nurse, may deduct expenditures for tuition, books, and transportation as business expenses under section 162(a), I.R.C. 1954,1 while attending a college program to qualify her to become a physician’s assistant.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits…
2Cases cited16 opinions
- Frank v. CommissionerUnited States Tax Court · 1953
- Davis v. CommissionerUnited States Tax Court · 1976
- Weiszmann v. CommissionerUnited States Tax Court · 1969
- Ronald F. Weiszmann and Deborah C. Weiszmann v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Glenn v. CommissionerUnited States Tax Court · 1974
11 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Soterios and Catharine Hantzis v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1981
- Robinson v. CommissionerUnited States Tax Court · 1982
- Radin v. CommissionerUnited States Tax Court · 1987
- Cristea v. CommissionerUnited States Tax Court · 1985
- Schneider v. CommissionerUnited States Tax Court · 1983
29 more not listed; retrieve them via the Exa API.