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

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.

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