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does and the nature of the courses offered by the academy, as
described in its catalog.
Respondent, although not necessarily agreeing that the
education maintained or improved petitioner’s skills as a golf
instructor, argues instead that the education expenses are not
deductible because the education leads to qualifying petitioner
in a new trade or business. Relying heavily on information
contained in the academy’s catalog, we agree with respondent.
As a successful graduate of the academy, petitioner was
awarded a specialized associate degree in business from an
educational institution accredited by the Accrediting Council for
Independent Colleges and Schools, Washington, D.C., and licensed
by the State Board of Independent Postsecondary, Vocational,
Technical, Trade and Business Schools, Florida Department of
Education. Some of the courses that petitioner took while
attending the academy no doubt maintained or improved his skills
as a golf instructor, but other courses were directed more to a
general business education. “If the education qualifies the
taxpayer to perform significantly different tasks and activities
than could be performed prior to the education, the education
qualifies the taxpayer for a new trade or business.” Kersey v.
Commissioner, T.C. Memo. 1993-641 (citing Glenn v. Commissioner,
62 T.C. 270 (1974)), affd. without published opinion 50 F.3d 15
(9th Cir. 1995). As the type of degree awarded to petitioner
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