This section contains the nature of the case and procedural background.

P was a tax attorney. To keep current in his profession, he attended the Fifth Annual Institute on Federal Taxation which was conducted in New York City by NYU. He incurred expenses for tuition of $305 which P claimed as an allowable deduction under section 23(a)(1)(A) as an ordinary and necessary expense in carrying on a trade or business. The IRS disallowed the deduction. The Tax Court upheld that decision with four judges dissenting. The court reasoned that it was not deductible because of the educational and personal nature of the object pursued by the petitioner. P contends that the expenses were directly connected with or proximately resulted from the practice of his profession. This appeal resulted.

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