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

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.

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