Toner v. Commissioner
United States Tax Court
P was a teacher in a Catholic elementary school in 1973. The minimum education required by her employer was a high school diploma, but teachers without a bachelor's degree were also required to earn 6 hours of college credits each year. Teachers in the public schools were generally required to have a bachelor's degree in order to begin teaching. P always planned to go to college and become a teacher.
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P was a teacher in a Catholic elementary school in 1973. The minimum education required by her employer was a high school diploma, but teachers without a bachelor's degree were also required to earn 6 hours of college credits each year. Teachers in the public schools were generally required to have a bachelor's degree in order to begin teaching. P always planned to go to college and become a teacher. In 1973, she took courses with 15 hours of credit, received her bachelor's degree, and deducted the expenses for such courses. Held, P's educational expenses are not deductible because the…
1Opinion of the Court
Simpson, Judge:
The Commissioner determined a deficiency of $177.41 in the petitioner’s Federal income tax for 1973. The sole issue to be decided is whether the petitioner, a teacher in a Catholic elementary school, may deduct as a business expense the cost of college courses leading to a bachelor’s degree.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioner, Linda M. Liberi Toner, maintained her legal residence in Broomall, Pa., at the time her petition was filed in this case. She filed her individual Federal income tax return for 1973 with the…
2Cases cited23 opinions
- Lemon v. KurtzmanSupreme Court of the United States · 1971
- Pierce v. Society of SistersSupreme Court of the United States · 1925
- Meek v. PittengerSupreme Court of the United States · 1975
- Sharon v. CommissionerUnited States Tax Court · 1976
- Davis v. CommissionerUnited States Tax Court · 1976
18 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Robinson v. CommissionerUnited States Tax Court · 1982
- Johnson v. CommissionerUnited States Tax Court · 1981
- Linda M. Liberi Toner v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1980
- Linda M. Liberi Toner v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1980
- Toner v. CommissionerUnited States Tax Court · 1981
11 more not listed; retrieve them via the Exa API.