P is a junior high school teacher who received her bachelor's degree in 1957. P believed that her teaching required greater depth of subject matter than she possessed. Because it would be difficult to obtain the coursework she wanted in history on a part-time basis, she arranged to attend Northwestern University as a full-time graduate student during the school year 1960-1. The Crookston school system does not customarily grant leaves of absence, and she resigned in June 1960. P got her masters and returned to teaching. She deducted the costs of the education from her taxes. The IRS (D) denied the deduction. P petitioned and the tax court, which held that she was not carrying on a trade or business while attending grad school full time and could not deduct. P appealed.

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

The legal issues presented in this case will be displayed here.

The court's holding and decision will be displayed here.

Legal analysis from Dean's Law Dictionary will be displayed here.