Legal Opinion

Brennan v. Commissioner

United States Tax Court

Decided September 10, 1963No. Docket No. 649-62UnpublishedCited by 4 opinions

The petitioner, an estate and gift tax examiner-reviewer for the Internal Revenue Service, completed a previously commenced night law school course in 1958. All of his fellow employees, including those whose work he reviewed, were law school graduates and members of the bar, and in the course of his official duties he conferred regularly with taxpayers' lawyers.

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The petitioner, an estate and gift tax examiner-reviewer for the Internal Revenue Service, completed a previously commenced night law school course in 1958. All of his fellow employees, including those whose work he reviewed, were law school graduates and members of the bar, and in the course of his official duties he conferred regularly with taxpayers' lawyers. Held: That the educational expenses were incurred primarily to maintain and improve petitioner's skills required by him in his employment and that such expenses are therefore deductible under section 162 of the 1954 Internal Revenue…

1Opinion of the Court

William J. Brennan and Lucile E. Brennan v. Commissioner.

Brennan v. Commissioner

Docket No. 649-62.

United States Tax Court

T.C. Memo 1963-243; 1963 Tax Ct. Memo LEXIS 103; 22 T.C.M. (CCH) 1222; T.C.M. (RIA) 63243;

September 10, 1963

The petitioner, an estate and gift tax examiner-reviewer for the Internal Revenue Service, completed a previously commenced night law school course in 1958. All of his fellow employees, including those whose work he reviewed, were law school graduates and members of the bar, and in the course of his official duties he conferred regularly with taxpayers' lawyers. Held:…

2Cases cited2 opinions

  1. Carlucci v. CommissionerUnited States Tax Court · 1962
  2. Welsh v. United StatesDistrict Court, N.D. Ohio · 1962

3Cited by4 opinions

  1. Campbell v. United StatesDistrict Court, E.D. Pennsylvania · 1966
  2. Louis H. Rombach and Ann M. Rombach v. The United StatesUnited States Court of Claims · 1971
  3. Berry v. CommissionerUnited States Tax Court · 1971
  4. Collins v. CommissionerUnited States Tax Court · 1973

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