Legal Opinion

Baker v. Commissioner

United States Tax Court

Decided November 12, 1968No. Docket No. 1678-67Published

Petitioner, after graduating from college, began working full time in March 1964 for his father's construction company as an engineer. From September 1964 until March 1967 he was a full-time law student, and during this period worked part time for the construction company. Upon graduation from law school he again became a full-time employee of the construction company. He was immediately elected to the position of vice president with a substantial increase in salary.

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Petitioner, after graduating from college, began working full time in March 1964 for his father's construction company as an engineer. From September 1964 until March 1967 he was a full-time law student, and during this period worked part time for the construction company. Upon graduation from law school he again became a full-time employee of the construction company. He was immediately elected to the position of vice president with a substantial increase in salary. Held, that the study of law was undertaken by petitioner primarily for personal purposes and, therefore, the expenses he…

1Opinion of the Court

N. Kent Baker, Petitioner v. Commissioner of Internal Revenue, Respondent

Baker v. Commissioner

Docket No. 1678-67

United States Tax Court

51 T.C. 243; 1968 U.S. Tax Ct. LEXIS 28;

November 12, 1968, Filed

Decision will be entered for the respondent.

Petitioner, after graduating from college, began working full time in March 1964 for his father's construction company as an engineer. From September 1964 until March 1967 he was a full-time law student, and during this period worked part time for the construction company. Upon graduation from law school he again became a full-time employee of the…

Also in this document: Concurrence · Drennen; Concurrence · Tannenwald; Dissent.

2Cases cited11 opinions

  1. Commissioner v. FlowersSupreme Court of the United States · 1946
  2. Commissioner v. StidgerSupreme Court of the United States · 1967
  3. Carroll v. CommissionerUnited States Tax Court · 1968
  4. Baker v. CommissionerUnited States Tax Court · 1968
  5. Booth v. CommissionerUnited States Tax Court · 1961

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