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22 Jun 2019

Carrie Hopkins is a qualified teacher in the San FranciscoUnified School District.

Currently, she teaches at North Lincoln High School where she isalso head of the

English Department. North Lincoln is a culturally diverse schoolwith a predominantly

Asian student population. As a department head, Carrie hasconsiderable input on

curriculum content of the courses offered by her school.

During the summer of 2014, Carrie enrolled in a course sponsoredby the University of

California, Berkeley Extension Program. The course, entitled“Southeast Asia: Sacred

Places,” was conducted in Thailand, Cambodia, and Indonesia anddealt with the effect of

religious traditions on the culture of Southeast Asia. Thecourse was taught by university

staff, and successful completion by a student qualified forundergraduate college credit.

The course is conducted overseas to enhance the significance ofthe subject matter

covered. Although Carrie’s employer approved of her academicendeavors, it did not

require her to take the course. Further, it did not reimburseher for any of the expenses

involved. Except for several minor sightseeing trips, Carriedevoted most of her time

during the course to the materials assigned and covered.

As a result of what she learned from the course she took, Carriemade various

improvements to the content of her department’s curriculum. Shealso feels that the

course increased her ability to understand and communicate withthe Asian students’ in

her classes.

On her Federal income tax return for 2014, Carrie dedicated allof the expenses incurred

in connection with the extension course. Upon audit by the IRS,the deduction is

disallowed. Who should prevail? And why?

Aid:

IRC 162(a) 262(a) and 274(m)(2)

Treasire. Reg. 1.162-5(e)

Takahshi v. Comm., T.C 126 (1986)

Jorgensen v. Comm., 79 TCM 1926, T.C Memo 2000-138

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Reid Wolff
Reid WolffLv2
24 Jun 2019

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