Furner v. Commissioner
United States Court of Appeals for the Seventh Circuit
393 F.2d 292 (1968)
Mary Furner (plaintiff), a junior-high teacher, took a one-year leave-free break to pursue full-time graduate study without her school system's formal leave approval, then immediately began teaching in a different school system right after earning her degree. She claimed a tax deduction for her graduate-school expenses; the Commissioner of Internal Revenue (defendant) disallowed it, reasoning she wasn't actively carrying on the trade or business of teaching while enrolled full-time without formal leave, following the Commissioner's usual policy of only allowing such deductions for study done during vacations, part-time during the school year, or full-time with the school's formal leave. The tax court sided with the Commissioner, relying on a precedent involving a nurse who took years of leave-based study largely unconnected to her nursing career, and Furner appealed.
Whether a federal taxpayer's education expenses may be tax deductible even where the taxpayer's trade or business is technically suspended while the expenses are incurred.