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tasks and activities performed at STC differed substantially from
the tasks and activities performed at Arthur Andersen.
In passing, petitioner mentions that his duties at
Williamson were not substantially different from his duties at
Arthur Andersen. While this contention may not be disputed, it
is not dispositive of the issue before us, because the record
does not support the conclusion that petitioner's temporary,
part-time work at Williamson established him in the trade or
business of accounting after he attended Emory. Indeed,
petitioner disavowed any intent to return to the accounting
profession at that time. Cf. Link v. Commissioner, 90 T.C. 460
(1988), affd. without published opinion 869 F.2d 1491 (6th Cir.
1989); Reisine v. Commissioner, T.C. Memo. 1970-310.
Accordingly, we hold that petitioner may not deduct the
educational expenses in issue. To reflect the concessions,
Decision will be entered
under Rule 155.
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