## Facts

- The taxpayer was a sixth-grade teacher in Sunnyvale, California, with a strong interest in science.
- In 1959, he spent $680 of personal funds to buy electronic equipment used in the school’s science lab; the equipment was not directly tied to the general science curriculum but was available for advanced student enrichment.
- The teacher sought reimbursement from the school for some of the equipment, and the school refused.
- In 1959, he also spent $473 to purchase three sets of encyclopedias after requesting that the school buy sets for classrooms; the school declined because encyclopedias were available in the school library.
- He used the encyclopedias only occasionally in his classroom and kept two sets at home and at another school where he taught.
- On his 1959 federal income tax return, he claimed deductions for the equipment and encyclopedia costs.
- The Commissioner disallowed the deductions in full, and the taxpayer petitioned the U.S. Tax Court to redetermine the resulting deficiency.

## Issues

1. Whether the teacher’s purchases of electronic equipment and encyclopedias were deductible as ordinary and necessary expenses paid or incurred in carrying on his trade or business as a teacher.
2. Whether the expenditures were instead nondeductible personal expenses or otherwise not currently deductible (including because of their character and use).

## Decision

- The Tax Court sustained the Commissioner’s disallowance of the claimed deductions.
- The court concluded the taxpayer did not establish entitlement to deduct the expenditures as business expenses for the taxable year at issue.

## Legal Principles

- A deduction is allowed only when the taxpayer proves the expenditure qualifies under the Internal Revenue Code and substantiates the amount and business connection.
- Trade-or-business expense deductions require a showing that the expense is ordinary and necessary to the taxpayer’s current trade or business.
- Personal expenses are not deductible, and mixed-use property costs may be disallowed when the taxpayer fails to prove primary business purpose or to allocate amounts to business use.
- The taxpayer bears the burden to show the Commissioner’s deficiency determination is incorrect.

## Conclusion

The Tax Court upheld the IRS’s denial of a teacher’s claimed deductions for school-related purchases where the taxpayer failed to prove the expenditures were ordinary and necessary teaching expenses rather than personal or otherwise non-deductible costs, and failed to substantiate qualifying business use.


Wheatland v. Comm’r, T.C. Memo. 1964-95 (1964)