- 13 -
Although he received part-time employment at the University as a
research assistant or associate, the work did not interfere with
his education; in fact, his research activities contributed to
his learning process as a graduate student.
In 1992, therefore, we hold that petitioner was not actively
engaged in a trade or business. His tuition expenses were
nondeductible personal education expenses. Sec. 262; see Lenihan
v. Commissioner, T.C. Memo. 1977-379.
Petitioner also contends that he is entitled to deduct his
tuition payments as amounts expended for the production of income
pursuant to section 212. For the reasons stated, supra, we
reject petitioner's argument and hold that the tuition payments
were nondeductible personal education expenses.
We have considered all arguments made by petitioner and, to
the extent not discussed above, find them to be without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011