Manocchio v. Commissioner
United States Tax Court
During 1977, petitioner, an airline pilot and an Air Force veteran, attended a flight-training course which maintained and improved skills required in his trade or business. Pursuant to 38 U.S.C. sec. 1677 (1976), he received checks from the Veterans' Administration (VA) totaling 90 percent of the cost of the classes and endorsed them over to the flight-training school.
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During 1977, petitioner, an airline pilot and an Air Force veteran, attended a flight-training course which maintained and improved skills required in his trade or business. Pursuant to 38 U.S.C. sec. 1677 (1976), he received checks from the Veterans' Administration (VA) totaling 90 percent of the cost of the classes and endorsed them over to the flight-training school. Because the payments received were exempt from taxation under 38 U.S.C. sec. 3101(a) (1976), petitioner did not report them on his 1977 Federal income tax return. He did, however, deduct the entire cost of the flight-training…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for the taxable year 1977 in the amount of $924. The only issue for decision is whether petitioner is entitled to deduct as educational expenses under section 1621 certain payments for flight-training expenses for which he received nontaxable reimbursement from the Veterans’ Administration.
This case was submitted fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts and attached exhibits are incorporated herein by reference. The pertinent facts are…
2Cases cited14 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- International Business MacHines Corporation v. The United StatesUnited States Court of Claims · 1965
- Estate of Emerson v. CommissionerUnited States Tax Court · 1977
- Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
9 more not listed; retrieve them via the Exa API.
3Cited by103 opinions
- John Manocchio v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Wendland v. CommissionerUnited States Tax Court · 1982
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
- Prabel v. CommissionerUnited States Tax Court · 1988
98 more not listed; retrieve them via the Exa API.