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Takahashi v. Commissioner

United States Tax Court
87 T.C. 126 (1986)


Facts

Mr. and Mrs. Takahashi (plaintiffs) were California science teachers, and many of their students came from ethnic minority groups. California law required all teachers to take educational courses relating to multicultural societies. The Takahashis independently traveled to Hawaii to attend a seminar on Hawaiian multiculturalism that was not required by their employer. While in Hawaii, the Takahashis spent nine of the trip’s 10 days in classroom instruction and multicultural-related field trips. The Takahashis deducted the costs of the trip as tax-deductible education expenses under § 162(a) of the federal tax code. The commissioner of internal revenue (commissioner) (defendant) disallowed the deduction, in relevant part because the Takahashis had not shown that the seminar costs were ordinary and necessary expenses of their business of teaching science. The Takahashis filed a petition challenging the commissioner’s decision.

Rule of Law

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Issue

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Holding and Reasoning (Nims, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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