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TONER v. C. I. R.

No. 79-2033.

623 F.2d 315 (1980)

Linda M. Liberi TONER, Appellant, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided June 16, 1980.

Attorney(s) appearing for the Case

Mary Ann Hagan (argued), Philadelphia, Pa., Marcus Schoenfeld (argued), Villanova, Pa., Robert Destro, Milwaukee, Wis., for appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Michael L. Paup, Gilbert S. Rothenberg (argued), Attys. Tax Div., Dept. of Justice, Washington, D. C., for appellee.

Before SEITZ, Chief Judge, ROSENN, Circuit Judge, and SHAPIRO, District Judge.

OPINION OF THE COURT

SEITZ, Chief Judge.

Linda M. Liberi Toner (the taxpayer) appeals a final decision of the Tax Court that determined a deficiency of $177.41 against her for deductions relating to her educational expenses.

I.

In 1971, taxpayer became a teacher at St. Clement's, a parochial school in the Archdiocese of Philadelphia. She taught both religious and secular subjects to fifth grade students. At the time of her initial employment...

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