Wassenaar v. Commissioner

72 T.C. 1195 (1979)

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Nature of the Case

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Facts

From 1963 until his beginning law school, P held numerous positions and worked for numerous employers, none of which were involved in any kind of taxation work. P graduated from Wayne State University Law School in June 1972. P was not employed during the summer following his graduation from law school; instead, he prepared for the Michigan bar, which he took in July 1972. P continued to search for employment with a law firm during such period. In October 1972, he passed the bar exam but was not formally admitted to the Michigan bar until May of 1973. In September 1972, P began courses in the graduate law program in taxation at New York University (NYU), and he graduated with a master’s degree in taxation in May 1973. P's principal residence was Holland, Mich., while he lived in New York to attend NYU during the year in issue. Following his graduation from NYU, P returned to Detroit to commence employment with the law firm of Miller, Canfield, Paddock & Stone (Miller firm). P deducted the expenses he incurred while attending NYU as an employee business expense. P deducted the expenses he incurred while attending NYU as an employee business expense. D disallowed the deduction on the ground that such expenses were not ordinary and necessary expenses paid or incurred in connection with any trade or business. P petitioned.