Glenn v. Commissioner

62 T.C. 270 (1974)

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Glenn v. Commissioner

United States Tax Court
62 T.C. 270 (1974)

Facts

William Glenn (plaintiff) was a public accountant licensed under Tennessee law and working at a national accounting firm. Glenn wanted to become a certified public accountant (CPA), which was a separate license under state law and a prerequisite to advancing to a manager or partner position at the accounting firm. In addition to the tasks performed by a public accountant, a CPA is qualified to advise clients on tax matters and represent them before governmental bodies. Further, CPAs can publicly hold themselves out as such and enjoy significant professional clout. In preparation for the CPA exam, Glenn took an intensive CPA review course at the University of Alabama that lasted for the month of October 1970. Glenn sat for the CPA exam in November 1970 and failed. On his 1970 income tax return, Glenn deducted the cost of the CPA review course and related expenditures as trade or business expenses. The commissioner of internal revenue (defendant) disallowed the deduction, and Glenn sought review in the tax court.

Rule of Law

Issue

Holding and Reasoning (Forrester, J.)

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Casebooks

Federal Income Tax

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