# Jungreis v. Commissioner > United States Tax Court · December 24, 1970 · 55 T.C. 581 URL: https://www.frixlaw.com/law-library/cases/4481696 ## Case - **Full name:** Arthur M. Jungreis, 1 v. Commissioner of Internal Revenue - **Court:** United States Tax Court - **Decided:** December 24, 1970 - **Citations:** 55 T.C. 581; 1970 U.S. Tax Ct. LEXIS 2 - **Precedential status:** Published - **Opinion:** Concurrence by Tannenwald - **Judges:** Dawson,Tannenwald,Quealy - **Cited by:** 36 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4481696 ## Opinion text TaNNENWAld, /., concurring: To me this case should be disposed of without engaging in the dialectics reflected by the majority opinion. In the first place, petitioner has not put the validity of respondent’s regulations in issue and those regulations specifically deny the claimed deduction. See sec. 1.162-5 (b) (2) (iii), Example (2), Income Tax Regs. In the second place, as I view the facts, petitioner herein worked because he studied. ITe did not study because he worked. On this basis alone, Marlor v. Commissioner, 251 F. 2d 615 (C.A. 2, 1958) reversing 27 T.C. 624 (1956), and United States v. Michaelsen, 313 I 2d 668 (C.A. 9, 1963), affirming Elmer R. Johnson, a Memorandum Opinion of this Court, are distinguishable. Qtjealy, /., agrees with this concurring opinion. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4481696. Public record. Not legal advice.