- 9 - deductible only if they are incurred to maintain or improve the taxpayer's employment or to meet the express requirements of the job. Sec. 1.162-5(a), Income Tax Regs. Educational expenses incurred to allow the taxpayer to meet the minimum educational requirements for his job qualification are considered personal expenses and are not deductible. Taubman v. Commissioner, 60 T.C. 814, 819 (1973) (law school expenses not deductible when legal education prepared taxpayer for new career); sec. 1.162-5(b), Income Tax Regs. In this case, petitioner is repaying money he received as a tuition scholarship while studying for his medical degree at Brown. A medical degree is a necessary step to practice medicine as a doctor. Repayment of these funds under the NHSC contract is therefore a personal expense because the funds were originally expended to enable him to enter into a new profession. Petitioner's interest payments are personal expenditures and not incurred in carrying on a trade or business. Deductions for them are disallowed under section 162. Section 163 - Interest Deduction Petitioner alternatively argues that his interest payments are deductible under section 163. Generally, section 163 provides that interest on indebtedness is deductible by the taxpayer in the year it is paid. Sec. 163(a). However, substantial limitations are placed on this general rule which mayPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011