Bryant v. Commissioner

66 T.C.M. 1594, T.C. Memo 1993-597 (1993)

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Bryant v. Commissioner

United States Tax Court
66 T.C.M. 1594, T.C. Memo 1993-597 (1993)

JC

Facts

Ellen Bryant (plaintiff) was a third-grade teacher at Tower Hill School. During the 1989 to 1990 school year, Tower Hill switched from written report cards to computerized reports for students. Starting in January 1991, elementary teachers had to prepare these reports on Macintosh-compatible technology. From January to August 1990, the school had eight Macintosh computers available for faculty and student use. From September to December 1990, the number had increased to 15 computers. In February 1990, Bryant purchased a $3,233 Macintosh computer so that she could prepare the reports at home. Bryant attempted to deduct depreciation on the computer on her income tax returns. However, the Commissioner of Internal Revenue (the commissioner) (defendant) disallowed that deduction because the computer was not obtained for the convenience of Tower Hill School and as a condition of Bryant’s employment. Bryant argued that because of the few available computers and the poor condition of the neighboring area and school security, Bryant would have been unable to timely prepare the required reports without her own computer. Evidence indicated that some other teachers did complete the reports on the school computers. Regardless, Bryant filed suit regarding the claimed deductions.

Rule of Law

Issue

Holding and Reasoning (Gussis, J.)

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