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Coughlin v. Commissioner

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Bloomberg Law

Citation. 203 F.2d 307, 1953 U.S. App. 53-1 U.S. Tax Cas. (CCH) P9321; 43 A.F.T.R. (P-H) 672

Brief Fact Summary. Petitioner worked at a law firm and specialized in tax matters. He attend a course in tax matters sponsored by New York University. He spent $305 in expenses attending the course and sought to deduct this as a business expense.

Synopsis of Rule of Law. Necessary expenses incurred in carrying on a trade or business are deductible if they are directly connected with or proximately resulted from the practice of a profession.


Facts. Petitioner was a member of a law firm and he specialized in tax matters. He attended the Fifth Annual Institute on Federal Taxation. He incurred expenses for tuition, travel and lodging of $305 and claimed that amount as a deduction of ordinary and necessary expenses incurred in carrying on a trade or business. The Commissioner did not allow the deduction and the Tax Court affirmed.

Issue. Should the expenses be allowed to be deducted as an ordinary and necessary business expenses?

Content Type: Brief


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