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CORBETT v. COMMISSIONER

Docket No. 4426-69SC.

55 T.C. 884 (1971)

PETER G. CORBETT AND AMARYLLIS E. CORBETT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 1, 1971.

Attorney(s) appearing for the Case

Peter G. Corbett, pro se.

Harvey R. Poe, for the respondent.

SIMPSON, Judge:

The respondent determined a deficiency of $401.23 in the petitioners' 1967 Federal income tax. The issue for decision is whether the petitioner was carrying on a trade or business within the meaning of section 162(a) of the Internal Revenue Code of 19541 while she was pursuing a course of study leading to a Ph.D. degree.

FINDINGS OF FACT

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