PATTERSON v. C. I. R.

No. 24113.

436 F.2d 359 (1971)

Samuel F. PATTERSON, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Ninth Circuit.

January 12, 1971.


Attorney(s) appearing for the Case

Samuel F. Patterson (argued), in pro. per.

Brobeck, Phleger & Harrison, San Francisco, Cal., for appellant.

William Massar (argued), Atty. Tax Div., Johnnie N. Walters, Asst. Atty. Gen., Richard M. Hahn, Acting Chief Counsel, Washington, D. C., for appellee.

Thomas Silk, for American Ass'n of University Professors, San Francisco, Cal., amicus curiae.

Before CHAMBERS, HAMLEY and HAMLIN, Circuit Judges.


PER CURIAM:

This is an appeal from a Tax Court decision in a proceeding for redetermination of a tax deficiency.

The taxpayer, Samuel F. Patterson, is an elementary school teacher in Los Angeles, 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...

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