United States Tax Court August 28, 1974, Docket No. 2530-73 (Garwood v. Commissioner)

lead-opinion

Simpson, Judge:

The respondent determined a deficiency of $254 in the Federal income tax of the petitioner for the year 1970. The only issue for decision is whether the expenses incurred by a substitute teacher in obtaining a bachelor of arts degree are deductible under section 162 of the Internal Revenue Code of 19541 as ordinary and necessary business expenses.