Hill v. Commissioner
United States Court of Appeals for the Fourth Circuit
181 F.2d 906 (1950)
Relevant factsFree
Nora Payne Hill (plaintiff), a Virginia high school teacher who needed periodic certificate renewal, chose to satisfy the renewal requirement by attending summer courses at Columbia University rather than taking an alternative qualifying exam, incurring $239.50 in expenses she deducted as a business expense; the Commissioner (defendant) disallowed the deduction as personal in nature, and the Tax Court affirmed, reasoning teachers did not ordinarily choose coursework over the exam and that Hill had not proven she was actually employed while taking the course.
IssueFree
Whether ordinary and necessary education expenses incurred while carrying on a trade or business are deductible.