James Carroll (plaintiff), a police officer, enrolled in university courses part time to pursue a major in philosophy with the ultimate goal of obtaining a law degree. Carroll’s employer had policies that encouraged police officers to pursue higher education, allowing Carroll to schedule work duties around his class schedule. Carroll deducted the cost of his university courses as expenses related to improving his job skills as a police officer. The federal tax commissioner (commissioner) (defendant) disallowed Carroll’s claim for a tax deduction. Carroll petitioned the United States Tax Court for a redetermination. The tax court entered judgment in favor of the commissioner. Carroll appealed to the United States Court of Appeals for the Seventh Circuit.