Coughlin (plaintiff) was an attorney in a New York firm. The nature of the firm’s work required that at least one of the firm’s lawyers be skilled in federal taxation. The firm depended on Coughlin to fulfill this obligation, which included the duty to keep himself regularly apprised of any developments in the field. In furtherance of this obligation, Coughlin attended a conference on federal taxation, incurring $305 in expenses. He claimed this amount as an ordinary and necessary business expense. The Commissioner (defendant) and the Tax Court disallowed the deduction, ruling that the expense was both educational and personal.