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to establish that the expense had a reasonably proximate
relationship to that trade or business. See Ferrer v.
Commissioner, 50 T.C. 177, 185 (1968), affd. per curiam 409 F.2d
1359 (2d Cir. 1969); see also Tokarski v. Commissioner, 87 T.C.
74, 77 (1986) (“we are not required to accept the self-serving
testimony of petitioner * * * as gospel”).
In the present case, petitioner was pursuing a doctoral
degree in an academic discipline that was unrelated to his trade
or business of being a Russian translator. Petitioner failed to
demonstrate that the cost of pursuing such a degree was
reasonably proximate to his trade or business. Indeed,
petitioner admitted that Davis Petroleum did not contact the
History Department of the University of Houston in search of a
Russian translator.13 The fact that petitioner was registered as
a doctoral candidate in the History Department at the time that
he was retained by Davis Petroleum does not, in our view, provide
a sufficient nexus between the cost of university enrollment and
petitioner’s particular trade or business. Were it otherwise,
the cost of university enrollment, regardless of the underlying
academic discipline, would be deductible as a business
13 We take notice of the fact that the Yellow Pages for
major metropolitan areas such as Houston, Texas, includes a
listing for “Translators & Interpreters”. We also take notice of
the fact that the American Translators Association maintains both
a Translation Services Directory and searchable On-Line
Directories (www.ATAnet.org) that list individuals and companies
that provide translation services.
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