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Namrow v. Commissioner

288 F.2d 648 (1960)

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Namrow v. Commissioner

United States Court of Appeals for the Fourth Circuit

288 F.2d 648 (1960)

Facts

Dr. Arnold Namrow (plaintiff) was a psychiatrist who was training in psychoanalysis. To become a psychoanalyst, a psychiatrist generally had to undergo several years of additional training from a specialized institute. Though psychiatrists were technically able to practice psychoanalysis without the training, they would be at a severe professional disadvantage: psychiatrists would not be recognized by the American Psychoanalytic Association and would not receive referrals for psychoanalytic patients. Namrow received his training at the Washington Psychoanalytic Institute. As part of his training, Namrow received personal analysis and paid for the services of supervising analysts. Namrow deducted the costs of his analysis and the supervising analysts from his income taxes, classifying the costs as education expenses. The Commissioner for Internal Revenue (the Commissioner) (defendant) held that the expenses were not tax-deductible because they were for learning a special skill that qualified Namrow for a new position or an advancement at his current position and that was beyond the ordinary skills of psychiatrists. Namrow petitioned the United States Tax Court for a redetermination. The tax court upheld the Commissioner’s decision, and Namrow appealed.

Rule of Law

Issue

Holding and Reasoning (Soper, J.)

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