Quimbee logo
DMCA.com Protection Status

Allemeier v. Commissioner

90 T.C.M. 197 (2005)

Case BriefQ&ARelatedOptions
From our private database of 22,600+ case briefs...

Allemeier v. Commissioner

United States Tax Court

90 T.C.M. 197 (2005)

Facts

Daniel Allemeier (plaintiff) worked at Selane Products (Selane) in a variety of positions for three years before getting a master’s degree in business administration (MBA). Before enrolling, the CEO of Selane told Allemeier that an MBA would enhance his skills and help him advance at the company. However, Selane did not require Allemeier to get an MBA and did not reimburse him for the cost. While getting his degree, Allemeier continued to work at Selane and was promoted several times during the course of the program. Allemeier deducted the cost of his tuition on his income-tax return as a business expense. The Commissioner of Internal Revenue (the Commissioner) (defendant) disallowed the deduction, arguing that the MBA was both a minimum education requirement for Allemeier’s continued employment at Selane and that the MBA qualified Allemeier for a new trade or business. Either argument would have barred Allemeier from deducting the cost of his MBA. Allemeier disagreed with both characterizations, instead arguing that his continued employment was not dependent on his getting an MBA and that the MBA would give him better background knowledge and improve his skills at work he was already engaged in. Allemeier petitioned the United States Tax Court for a redetermination.

Rule of Law

Issue

Holding and Reasoning (Kroupa, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 519,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 519,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 22,600 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions and answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Access this case brief for FREE

With a 7-day free trial membership
Here's why 519,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 22,600 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership