Thursday, August 11, 2016
Tanzi v. Commissioner, T.C. Memo. 2016-148 (Aug. 9, 2016):
During the first half of 2011 the Tanzis were employed by Seminole State College. Dr. Tanzi taught math and communications classes as an adjunct professor, and Mrs. Tanzi was employed as a campus librarian.
Dr. Tanzi is highly educated—he holds a doctorate in communication. As he explained at trial, individuals holding such terminal degrees bear a lifelong burden of “developing knowledge, finding knowledge, exploring, [and] essentially selfeducating”. Dr. Tanzi therefore insists that all expenses paid in adding to his “general knowledge” should be deductible as unreimbursed employee business expenses. ...
The Tanzis argue they are entitled to a $741 deduction for home Internet expenses. The Tanzis provided receipts showing they paid the expenses. Dr. Tanzi argued he should be entitled to deduct the full amount on the basis that all Internet access contributed to increasing his “general knowledge”. We find this argument unpersuasive. Use of the Internet in the pursuit of “general knowledge” does not strike us as an ordinary and necessary business expense for a college professor. It is more in the nature of a personal expense. Accordingly, we find that the Tanzis are not entitled to deduct their home Internet expenses [and cell phone expense, computer equipment, books, CDs, DVDs, DirecTV]. ... Dr. Tanzi even admitted that he is aware of no university that requires professors to purchase these additional materials and services in carrying out their jobs. ... While we find credible the Tanzis’ testimony that they spent significant time and resources educating themselves, we do not believe the expenses are ordinary and necessary for the trades of being a professor or a campus librarian but rather are personal, living, or family expenses nondeductible under section 262(a).