HILL V. COMMISSIONER
181 F.2d 906 (4th Cir. 1950)
NATURE OF THE CASE: This was a dispute over the deduction of summer school expenses for
the renewal of a teaching license. Hill (P) filed an action seeking relief from a ruling
that there was a deficiency in the income tax due for the calendar year 1945.
FACTS: P was engaged in teaching school in Virginia. She attended summer school at
Columbia University for which she incurred expenses of $239.50. She deducted that amount
from her net income to compute her 1945 taxes. The IRS disallowed those expenses on the
grounds that they were personal. P was required by state law to periodically renew her
teaching license. This could be done by summer school or by reading or passing a written
exam. P chose to renew by attending summer school. P claimed that these expenses were
necessary and ordinary for her to continue in her business. The tax court agreed with the
IRS and ruled that attending summer school was not an ordinary way to renew a teaching
certificate. This appeal resulted.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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