repeating the importance of “consideration of the relationship of the education with intended future resumption of business activity”
How later courts described this case
- repeating the importance of “consideration of the relationship of the education with intended future resumption of business activity”
- teacher who took year off to secure masters degree was still carrying on a trade or business and allowed to deduct educational expenses
Written by the judges who cited it.
The opinion
Tannenwald, /., concurring: I concur in the result reached by the majority solely on the ground that under the facts and circumstances of this case the taxpayer was not carrying on a trade or business during the taxable period in question within the meaning of section 162(a).