Burnstein v. Commissioner
United States Tax Court
Held, although T had a master of education degree and not only taught dyslexic (learning-disabled) children but also counseled their parents on how to deal with them at home, her educational expenses incurred in obtaining a degree of master of social work (M.S.W.) were nondeductible because such education went beyond merely improving her skills and led "to qualifying [her] in a new trade or business." Sec. 1.162-5(b)(3)(i), Income Tax Regs.
1Opinion of the Court
Raum, Judge:
The Commissioner determined a deficiency of $1,728.70 in petitioners’ 1971 income tax. The sole issue before us is the deductibility of certain educational expenses incurred by petitioner Muriel Burnstein in the course of obtaining a master of social work degree.
FINDINGS OF FACT
The parties have submitted a stipulation of facts which, together with the exhibits attached thereto, is incorporated herein by this reference.
Petitioners Myron and Muriel Burnstein are husband and wife. They resided in New Orleans, La., on the date of the filing of the petition herein. Myron is a party to…
2Cases cited7 opinions
- Carroll v. CommissionerUnited States Tax Court · 1968
- James A. And Isabelle Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
- Bodley v. CommissionerUnited States Tax Court · 1971
- O'Donnell v. CommissionerUnited States Tax Court · 1974
- Jungreis v. CommissionerUnited States Tax Court · 1970
2 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Toner v. CommissionerUnited States Tax Court · 1979
- Voigt v. CommissionerUnited States Tax Court · 1980
- Cristea v. CommissionerUnited States Tax Court · 1985
- Ardavany v. CommissionerUnited States Tax Court · 1979
- Burnstein v. CommissionerUnited States Tax Court · 1976
9 more not listed; retrieve them via the Exa API.