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In 1992, petitioner became a certified candidate. Prior to
entering the candidacy for ministry, petitioner accumulated over
60 undergraduate semester hours from various schools, which met
the minimum undergraduate educational requirements to become an
associate member.
Petitioner decided that he needed to improve his ministry
skills. Such skills included interpersonal skills, relational
skills (e.g., working with situations in which parishioners could
be involved), sermon writing skills, leadership skills, and
management skills. In 1994, petitioner decided to take courses
at the University of Great Falls.6 These courses were not
required for petitioner to continue as a local pastor. In
December 1995, petitioner earned a bachelor’s degree in human
services.
On their joint 1994 tax return, petitioners claimed a
deduction of $9,698 for “Continuing Education” on their Schedule
C, Profit or Loss From Business. The amount claimed represented
tuition, books, and course-related fees incurred and paid by
petitioner for the courses taken at the University of Great
Falls. In the notice of deficiency, respondent disallowed the
deduction, stating:
6 Examples of courses taken by petitioner include:
Introduction to Counseling, Internship in Ministry Practice,
Death and Dying as a Life Cycle, Modern Social Problems, The
Family, Community, Ethics in Human Services, Symphonic Choir,
Basic Writing, and Writing Strategies.
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Last modified: May 25, 2011