- 10 -
In view of the foregoing, we sustain respondent’s
determination and hold that petitioner is not entitled to any
deduction for cellular telephone expense.
C. Educational Expense
Petitioner claims that he paid $1,550 for “continuing
education”. At trial, petitioner testified that this amount
represents what he paid to the University of Houston for
“dissertation hours” in the pursuit of a Ph.D degree in
history.10 The record does not include any documentary evidence
showing that petitioner paid any particular amount of money to
the University of Houston. Regardless, the record does not
demonstrate that there was a “proximate and direct relationship”
between any educational expense that petitioner may have incurred
in pursuing a course of study in the History Department and his
job skills as a Russian translator.11 See Carroll v.
Commissioner, 51 T.C. 213, 218 (1968), affd. 418 F.2d 91 (7th
Cir. 1969); see also Schwartz v. Commissioner, 69 T.C. 877, 889
(1978); Zimmer v. Commissioner, T.C. Memo. 1992-678; sec. 1.162-
5(a), Income Tax Regs.; cf. sec. 1.162-5(b)(1), Income Tax Regs.
10 Petitioner gave the impression that the focus of his
doctoral studies was American history when he testified that “I
actually passed my orals in U.S. history”.
11 Although petitioner’s work as a research assistant for
the History Department dealt with Russian medieval history,
petitioner’s academic orientation was apparently toward U.S.
history. See supra note 4.
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