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involved in and intended to return to a particular trade or
business. Id. In order to take advantage of what has been
described as the "hiatus" principle, a taxpayer must show that
during the hiatus he intended to resume the same trade or
business. See Estate of Rockefeller v. Commissioner, 762 F.2d
264, 270 (2d Cir. 1985) (citing Sherman v. Commissioner, T.C.
Memo. 1977-301), affg. 83 T.C. 368 (1984). If substantial
differences exist in the tasks and activities of the employments
undertaken before and after the period of education, then each
employment constitutes a separate trade or business. Davis v.
Commissioner, 65 T.C. 1014, 1019 (1976). For example, this Court
has held that a helicopter pilot is engaged in a different trade
or business than an airline pilot. Lee v. Commissioner, T.C.
Memo. 1981-26, affd. 723 F.2d 1424 (9th Cir. 1974). Similarly,
we have held that a licensed practical nurse is not in the same
trade or business as a registered nurse. Reisinger v.
Commissioner, 71 T.C. 568 (1979).
Petitioner asserts that, under the hiatus principle, he was
engaged in a trade or business as a "tax consultant" while
earning his LL.M. at Emory, because in his view he was employed
as a "tax consultant" both before and after his enrollment at
Emory. Petitioner primarily relies on a comparison of his duties
at Arthur Andersen with his duties at STC. Respondent contends
that the nature of petitioner's employment differed substantially
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