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Respondent determined a deficiency of $2,593 in petitioner’s
1995 Federal income tax. The issue for decision is whether
petitioner is entitled to deduct, as trade or business expenses,
tuition costs and related expenses incurred in attending the Golf
Academy of the South.
Background
This case was submitted fully stipulated, and the stipulated
facts are so found. Petitioner resided in Mason, Ohio, at the
time the petition was filed.
During 1995, petitioner was employed in a variety of ways.
According to the stipulation of facts, he “worked full time in
construction and was self-employed as a golf instructor and
worked at golf courses in the pro shops.”
Beginning in 1994, petitioner enrolled as a student at the
Golf Academy of the South (the academy). The academy is
accredited as a business school by the Accrediting Council for
Independent Colleges and Schools, Washington, D.C.; it is
licensed by the State Board of Independent Postsecondary,
Vocational, Technical, Trade and Business Schools, Florida
Department of Education. Successful graduates of its 2-year
program are awarded a specialized associate degree in business.
Courses offered by the academy are approved for the training of
veterans and persons eligible for VA educational benefits.
Subject to certain conditions and limitations, the academy
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