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Furner v. Commissioner

United States Court of Appeals for the Seventh Circuit
393 F.2d 292 (1968)


Facts

Mary Furner (plaintiff) was a junior-high school teacher. To improve her teaching skills, Furner enrolled in a one-year graduate-school course. Furner’s school system did not grant her leave to attend graduate school. Immediately after receiving her graduate degree, Furner began teaching in another school system. Furner claimed an education-expense tax deduction for the cost of obtaining her graduate degree. The commissioner of internal revenue (commissioner) (defendant) determined that Furner’s graduate-school expenses were not tax deductible because Furner was not carrying on the trade or business of teaching when she incurred those expenses. The commissioner disallowed Furner’s education-expenses deduction, and Furner petitioned the tax court for a redetermination. The tax court ruled for the commissioner. Furner appealed, arguing that teachers often pursued full-time graduate education for one year without leave before taking a new teaching position afterward.

Rule of Law

Issue

Holding and Reasoning (Fairchild, J.)

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