Wassenaar v. Commissioner
United States Tax Court
1. P graduated from law school in May 1972. In September 1972, he commenced a graduate law program and graduated with a masters degree in taxation in May 1973. P never practiced law before his enrollment in the program and was not admitted to the bar until May 1973. Held, P's educational expenses are not deductible under sec. 162(a), I.R.C. 1954, as ordinary and necessary expenses incurred in a trade or business.
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1. P graduated from law school in May 1972. In September 1972, he commenced a graduate law program and graduated with a masters degree in taxation in May 1973. P never practiced law before his enrollment in the program and was not admitted to the bar until May 1973. Held, P's educational expenses are not deductible under sec. 162(a), I.R.C. 1954, as ordinary and necessary expenses incurred in a trade or business. Held, further, such expenses are not deductible under sec. 212(3), I.R.C. 1954, relating to the determination of tax liability. 2. P incurred expenses in moving from New York City,…
1Opinion of the Court
Simpson, Judge:
The Commissioner determined a deficiency of $521 in the petitioner’s Federal income tax for 1973. The issues for decision are: (1) Whether the petitioner may deduct as an ordinary and necessary business expense the cost of his masters of law degree in taxation; (2) whether such expenses are deductible under section 212(3) of the Internal Revenue Code of 1954,1 as ordinary and necessary expenses paid in connection with the determination of tax liability; and (3) whether the expenses the petitioner incurred in moving from New York to Detroit to commence employment are deductible…
2Cases cited23 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Primuth v. CommissionerUnited States Tax Court · 1970
- Carroll v. CommissionerUnited States Tax Court · 1968
- James A. And Isabelle Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
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3Cited by21 opinions
- Boser v. CommissionerUnited States Tax Court · 1981
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- Weyts v. Comm'rUnited States Tax Court · 2003
- Hooks v. CommissionerUnited States Tax Court · 1993
- Boser v. CommissionerUnited States Tax Court · 1981
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