Joseph S. Conover, Jr., and Carol T. Conover v. Commissioner of Internal Revenue

Third Circuit

Joseph S. Conover, Jr., and Carol T. Conover v. Commissioner of Internal Revenue

380 F.2d 380, 20 A.F.T.R.2d (RIA) 5030, 1967 U.S. App. LEXIS 5724

CourtCourt of Appeals for the Third Circuit

DecidedJuly 5, 1967

Docket16345

StatusPublished

Cited by1 cases

This text of 380 F.2d 380 (Joseph S. Conover, Jr., and Carol T. Conover v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Joseph S. Conover, Jr., and Carol T. Conover v. Commissioner of Internal Revenue, 380 F.2d 380, 20 A.F.T.R.2d (RIA) 5030, 1967 U.S. App. LEXIS 5724 (3d Cir. 1967).

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Opinion

OPINION OF THE COURT

PER CURIAM.

This is an appeal from the decision of the Tax Court disallowing the taxpayers’ claimed educational expenses. The Tax Court found that the expenses the taxpayer incurred in taking courses leading to a degree in mechanical engineering, while employed to do general maintenance and electrical work at a country club, were not expenditures made for education undertaken primarily for the purpose of maintaining or improving skills required by him in his employment or other trade or business, or of meeting the express requirements of his employer imposed as a condition to the retention of his salary status, or employment. An examination of the record discloses that there was substantial evidence to support this finding, and it will not be disturbed here.

The judgment of the Tax Court will be affirmed.

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OPINION OF THE COURT

PER CURIAM.

This is an appeal from the decision of the Tax Court disallowing the taxpayers’ claimed educational expenses. The Tax Court found that the expenses the taxpayer incurred in taking courses leading to a degree in mechanical engineering, while employed to do general maintenance and electrical work at a country club, were not expenditures made for education undertaken primarily for the purpose of maintaining or improving skills required by him in his employment or other trade or business, or of meeting the express requirements of his employer imposed as a condition to the retention of his salary status, or employment. An examination of the record discloses that there was substantial evidence to support this finding, and it will not be disturbed here.

The judgment of the Tax Court will be affirmed.

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Bluebook (online)

380 F.2d 380, 20 A.F.T.R.2d (RIA) 5030, 1967 U.S. App. LEXIS 5724, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-s-conover-jr-and-carol-t-conover-v-commissioner-of-internal-ca3-1967.

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