CARROLL V. COMMISSIONER
418 F.2d 91 (7th Cir. 1969)
NATURE OF THE CASE: This was a dispute over an educational expense. Carroll (P), husband
and wife, appealed an order of the Tax Court, which disallowed their deduction of certain
educational expenses.
FACTS: Carroll (P) was a detective with the Chicago Police Department. In 1964, he
deducted $720.80 for the cost of his enrollment in DePaul University. P stated the purpose
was to prepare for law school and consisted of a major in Philosophy. P justified the
deduction under 162(a) as an expense relating to improving job skills to maintain his
position as a detective. The courses were on English, Philosophy, History and Political
Science. The Department had a General Order, which encouraged attendance at colleges and
universities.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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