Osborn v. Commissioner
United States Tax Court
Amounts paid by a scholar for research assistance in his work on three publications, from none of which he expects to derive profit, the purpose of his work and expense being to increase his prestige and to improve his reputation for scholarship and learning and thus attract opportunities of positions in the field of education, held, not deductible as ordinary and necessary expenses of carrying on a trade or business.
1Opinion of the Court
OPINION.
Sternhagen, Judge-.
The taxpayer, a research professor at Yale, claims the right to deduct expenses paid by him for services incident to the preparation and publication of scholarly and literary matter from which he did not, and did not expect to, derive a direct or immediate profit, but which he hoped and expected would be a means of demonstrating his ability and attainments to persons in the fields of learning and education and would thus bring him a lucrative position, perhaps as a college president. The statutory provision upon which the claimed deduction is based is section 23 (a)…
2Cases cited1 opinion
- Welch v. HelveringSupreme Court of the United States · 1933
3Cited by18 opinions
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
- Owen v. CommissionerUnited States Tax Court · 1954
- Matilda M. Brooks v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Bolt v. CommissionerUnited States Tax Court · 1968
- Riddle v. United StatesDistrict Court, D. Colorado · 1962
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