John D. And Karla Kay Glasgow v. Commissioner of Internal Revenue

Tenth Circuit

John D. And Karla Kay Glasgow v. Commissioner of Internal Revenue

486 F.2d 1045, 32 A.F.T.R.2d (RIA) 6113, 1973 U.S. App. LEXIS 7107

CourtCourt of Appeals for the Tenth Circuit

DecidedNovember 9, 1973

Docket72-1640

StatusPublished

Cited by12 cases

This text of 486 F.2d 1045 (John D. And Karla Kay Glasgow v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

John D. And Karla Kay Glasgow v. Commissioner of Internal Revenue, 486 F.2d 1045, 32 A.F.T.R.2d (RIA) 6113, 1973 U.S. App. LEXIS 7107 (10th Cir. 1973).

Pincite

Opinion

PER CURIAM.

This appeal is taken by the Commissioner from a decision of the Tax Court, 31 T.C.M. 310, holding that petitioners-appellees were entitled to a 1967 income tax deduction for educational expenses as ordinary and necessary business expenses under section 162(a) of the Internal Revenue Code of 1954 and the 1958 regulation, Treas.Reg. § 1.162-5, T.D. 6291, 1958-1 Cum.Bull. 63; 26 C.F.R. § 1.162-5, Rev. 1958.

The expenses incurred were for undergraduate educational courses pursued by petitioner John D. Glasgow while serving as a Baptist minister. On the record we feel the issue was essentially a question of fact. We are satisfied that the findings and conclusions of the Tax Court as the trier of fact, as stated in its opinion, are not clearly erroneous and should therefore not be disturbed. Commissioner of Internal Revenue v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L. Ed.2d 1218.

Affirmed.

Free access — add to your briefcase to read the full text and ask questions with AI

PER CURIAM.

This appeal is taken by the Commissioner from a decision of the Tax Court, 31 T.C.M. 310, holding that petitioners-appellees were entitled to a 1967 income tax deduction for educational expenses as ordinary and necessary business expenses under section 162(a) of the Internal Revenue Code of 1954 and the 1958 regulation, Treas.Reg. § 1.162-5, T.D. 6291, 1958-1 Cum.Bull. 63; 26 C.F.R. § 1.162-5, Rev. 1958.

The expenses incurred were for undergraduate educational courses pursued by petitioner John D. Glasgow while serving as a Baptist minister. On the record we feel the issue was essentially a question of fact. We are satisfied that the findings and conclusions of the Tax Court as the trier of fact, as stated in its opinion, are not clearly erroneous and should therefore not be disturbed. Commissioner of Internal Revenue v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L. Ed.2d 1218.

Affirmed.

Cite This Page — Counsel Stack

Bluebook (online)

486 F.2d 1045, 32 A.F.T.R.2d (RIA) 6113, 1973 U.S. App. LEXIS 7107, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-d-and-karla-kay-glasgow-v-commissioner-of-internal-revenue-ca10-1973.

Opinion

Related

Cite This Page — Counsel Stack