Gallery v. Commissioner
United States Tax Court
In 1966 petitioner enrolled as a junior in the College of Engineering at the University of Detroit in Michigan. The university made available to students, including petitioner, the opportunity to be employed by Ford Motor Co. in the latter's "College Cooperative Program" which afforded students the opportunity to test career interests and aptitudes on major assignments closely related to their college major in preparation for a potential career with Ford or another firm.
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In 1966 petitioner enrolled as a junior in the College of Engineering at the University of Detroit in Michigan. The university made available to students, including petitioner, the opportunity to be employed by Ford Motor Co. in the latter's "College Cooperative Program" which afforded students the opportunity to test career interests and aptitudes on major assignments closely related to their college major in preparation for a potential career with Ford or another firm. Petitioner participated in this program and in April 1967 he concluded his first cooperative work period at Ford's Buffalo,…
1Opinion of the Court
Withey, Judge:
Respondent determined a deficiency in petitioners’ joint Federal income tax for tlie year 1967 in the amoimt of $175.73.
The only issue for decision is whether petitioners are entitled to deductions claimed for education, travel, meals, and lodging incurred by Thomas W. Gallery in 1967 while attending the College of Engineering at the University of Detroit in Michigan.
FINDINGS OF FACT
Some of the facts have been stipulated and together with stipulated exhibits are so found and incorporated herein by this reference.
The petitioners, Thomas W. and Jennifer A. Gallery, are husband and…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Fischer v. CommissionerUnited States Tax Court · 1968
- Weiszmann v. CommissionerUnited States Tax Court · 1969
- 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 by2 opinions
- Cristea v. CommissionerUnited States Tax Court · 1985
- Gallery v. CommissionerUnited States Tax Court · 1971