Namrow v. Commissioner
United States Court of Appeals for the Fourth Circuit
288 F.2d 648 (1960)
- Written by Heather Whittemore, JD
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.)
What to do next…
Here's why 825,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,400 briefs, keyed to 989 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
