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P received a bachelor of laws degree in June 1964. P expended a total of $210.20 in gaining admission to practice law in the State of New York. This amount included $175.20 for bar review courses and materials related thereto and a New York State bar examination fee of $25. P was admitted to practice law and was employed as an attorney by a law firm in New York City until 1967, when he accepted a position in the Office of Regional Counsel, Internal Revenue Service, and moved to California. The IRS (D) did not him to be a member of the California bar. P spent $801 in order to gain membership in the California bar. P also spent a total of $11 in order to be admitted to practice before the U.S. District Court for the Northern District of California and the U.S. Court of Appeals for the Ninth Circuit. D required only that he be admitted to practice before the U.S. Tax Court. The IRS (D) did not him to be a member of the California bar. P spent $801 in order to gain membership in the California bar. P also spent a total of $11 in order to be admitted to practice before the U.S. District Court for the Northern District of California and the U.S. Court of Appeals for the Ninth Circuit. D required only that he be admitted to practice before the U.S. Tax Court. P also spent $313.35 in gaining admission to the Supreme Court. This was not required for work but the head of D’s legal department and two of P’s supervisors supported the admission. P claimed deductions for these educational and licensing expenses and almost all of them were disallowed by D. P petitioned.

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