Samuel F. Patterson v. Commissioner of Internal Revenue
Opinion
Opinion
This is an appeal from a Tax Court decision in a proceeding for redetermi-nation of a tax deficiency.
The taxpayer, Samuel F. Patterson, is an elementary school teacher in Los An-geles, California. In his federal income tax return for 1963, he deducted, as ordinary and necessary business expenses, amounts assertedly incurred (1) in doing research toward a doctoral degree in education, and (2) in equipping and operating a special room at his school to provide students with supplemental learning experiences. The deductions were disallowed by the Commissioner of Internal Revenue and he was assessed a deficiency in the amount of $510.97 for 1963.
Patterson, appearing in propria persona, petitioned the Tax Court for a re-determination of the deficiency. In its decision the Tax Court upheld the Commissioner’s disallowance of taxpayer’s claimed business expense deductions on two grounds. One ground was that expenditures of the kind described are, as a matter of law, not deductible. The other ground was that Patterson failed to substantiate the amounts of the claimed expenditures. Patterson, again proceeding in propria persona, appealed to this court.