- 2 -
Respondent determined deficiencies in petitioner's Federal
income taxes for the taxable years 1990 and 1991 in the amounts
of $641 and $776, respectively.
After concessions, the sole issue is whether petitioner is
entitled to deduct as educational expenses costs incurred
obtaining a master of laws (LL.M.) in taxation under section 162.
Petitioner resided in Columbia, South Carolina, at the time he
filed his petition.
FINDINGS OF FACT
Petitioner graduated from The Citadel in 1984 with a B.S.
degree in business administration. Soon thereafter, petitioner
enrolled at the University of South Carolina (USC). In December
1987, petitioner graduated from USC with a J.D. degree and a
master's in taxation from the business school. Petitioner
accepted a position on the tax staff of Arthur Andersen & Co.
(Arthur Andersen) in January 1988. At Arthur Andersen,
petitioner spent approximately 30 to 40 percent of his time
preparing tax returns, 40 to 50 percent researching the tax law,
and the remainder consulting clients about tax matters.
In March 1990, petitioner quit his job at Arthur Andersen.
After leaving Arthur Andersen, petitioner worked for John Shell
Associates, Inc., a temporary accounting firm for 4 weeks.
Petitioner did not plan to rejoin either firm. He then went on
active duty with the National Guard and completed an advanced
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011