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Wheatland v. Commissioner

T.C. Memo 1964-95 (1964)

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Wheatland v. Commissioner

United States Tax Court

T.C. Memo 1964-95 (1964)

Facts

Jack Wheatland (plaintiff) was a sixth-grade teacher in Sunnyvale, California, from 1954 to 1962. Wheatland was particularly interested in science and contributed several items to the school’s science laboratory library (the lab). In 1959, Wheatland spent $680 of his own money to buy electronic equipment for the lab. The equipment was not directly related to the general science curriculum but was available for use by students seeking more advanced science enrichment. On one occasion he sought reimbursement for some of the equipment from the school and was refused. Also in 1959, Wheatland spent $473 to purchase three sets of encyclopedias. Wheatland requested that the school purchase enough sets for use in each classroom, but his request was denied because there were encyclopedias available for student use in the school library. Wheatland occasionally used the encyclopedias he purchased in his classroom but kept two sets at home and at another school where he taught. On his 1959 tax return, Wheatland claimed a deduction based on the expenses he incurred for the electronic equipment and the encyclopedias. The commissioner of internal revenue (defendant) disallowed the deductions entirely.

Rule of Law

Issue

Holding and Reasoning (Drennen, J.)

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