Samuel Ochs (plaintiff) had a wife who was diagnosed with throat cancer. His wife’s efforts to speak were painful and worsened her condition. A reputable physician advised Ochs that his wife would not improve unless their two children, aged six years and four years, were separated from her. At significant expense, Ochs enrolled the children in boarding school until his wife recovered, after which time the children returned to public school. Ochs claimed a medical-care tax deduction for the boarding-school expenses. The federal tax commissioner (commissioner) (defendant) denied the tax deduction, asserting that costs for boarding school were personal expenses, not medical-care expenses. Ochs petitioned the United States Tax Court for a redetermination. The tax court entered judgment for the commissioner. Ochs appealed to the United States Court of Appeals for the Second Circuit.