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Sharon v. Commissioner

United States Tax Court
66 T.C. 515 (1976)


Facts

To be licensed to practice law in New York, Joel Sharon (plaintiff) had to graduate from college and law school and pass the New York bar examination (exam). Sharon incurred costs for college and law school, as well as a bar-exam study course. After graduating and passing the bar, Sharon practiced law in New York. However, Sharon later moved to California, where he found employment as a lawyer with the regional office of the Internal Revenue Service (IRS). The IRS did not require Sharon to obtain a California law license, but Sharon thought that studying for the California bar exam would help him in his IRS work. Sharon paid for a California bar-exam study course, passed the exam, and was admitted to the California bar. Sharon subsequently was admitted to the bar of the California federal courts. Sharon deducted the costs of his college, law school, and bar-exam study courses as tax-deductible education expenses under § 162 of the federal tax code and the amortization-deduction provisions of § 167 of the tax code. The commissioner of internal revenue (commissioner) (defendant) determined that Sharon’s expenses were non-deductible personal expenses, and disallowed Sharon’s deduction. Sharon petitioned the tax court for a redetermination.

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Holding and Reasoning (Simpson, J.)

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Dissent (Irwin, J.)

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