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suggests, petitioner’s education at the academy, which included
numerous business courses, qualifies him for trades or businesses
other than that of golf instructor.
We also find it significant that upon being awarded an
associate’s degree from the academy, petitioner could, as the
catalog states, “expect to earn a bachelor’s degree in two
academic years” at another institution. Simply put, the
educational expenses here in dispute were incurred in the course
of obtaining a basic undergraduate degree, even if many of the
courses directly related to petitioner’s trade or business at the
time. We think it is axiomatic that in the case of an individual
who holds no prior undergraduate degrees, a college education
leads to qualifying that individual for a variety of new trades
or businesses. Cf. Carroll v. Commissioner, 51 T.C. 213 (1968),
affd. 418 F.2d 91 (7th Cir. 1969).
In this case, we find that the education expenses were
incurred in the course of study that would lead to qualifying
petitioner, who held no prior undergraduate degrees, in trades or
businesses other than as a golf instructor. It follows that the
education expenses are not deductible, and we so hold.
Respondent’s adjustment in this regard is therefore sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
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Last modified: May 25, 2011