Jorgenson v. Commissioner
United States Tax Court
T.C. Memo 2000-138, 79 T.C.M. (CCH) 1926 (2000)
- Written by Whitney Punzone, JD
Facts
In 1995 and 1996, Ann Jorgenson (plaintiff) claimed deductions for travel and educational expenses incurred while participating in university courses in Greece and Southeast Asia sponsored by the University of California, Berkeley Extension Program. Jorgenson was a high school English teacher and chair of the English department. Most of Jorgenson’s responsibilities as an English teacher centered on cultural diversity. Jorgenson claimed deductions for 1995 and 1996 in the amounts of $5,574 and $7,805, respectively. In 1995 Jorgenson claimed $240 for hotel accommodations for two extra nights. Jorgenson was an active participant in the courses, although her employer did not require her to take the courses. Jorgenson took the knowledge obtained from the courses to enhance and develop curriculum, understand her students better, and engage in discussions about culture. The commissioner of internal revenue (defendant) disallowed the 1995 and 1996 deductions. The commissioner argued that the expenses were incurred for travel as a form of education and were nondeductible under Internal Revenue Code (IRC) § 274(m)(2). Alternatively, the commissioner argued that the expenses were not ordinary and necessary business expenses under IRC § 162.
Rule of Law
Issue
Holding and Reasoning (Dean, J.)
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