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Respondent determined a deficiency of $3,940 in petitioner’s
Federal income tax for 1996. Petitioner conceded that he is not
entitled to a deduction for education expenses relating to his
wife. Thus, we must decide whether the expense incurred for
pilot training is deductible from petitioners’ gross income under
section 162. We hold that it is.
Background
The stipulation of facts and the accompanying exhibits are
incorporated herein by reference. Petitioner resided in
Kingwood, Texas, at the time the petition in this case was filed.
In the 1980s, petitioner served in the U.S. military.
Petitioner retired from the service in 1991. While in the
service he trained on and was certified to fly helicopters. He
served as a helicopter test pilot. Petitioner also flew and was
familiar with the systems and operations of a U-21 aircraft, a
military version of the Beech 1900D, a fixed-wing aircraft.
In 1984, petitioner received the Federal Aviation
Administration’s (FAA) certified fixed-wing private rating,
allowing him to fly a small single-engine aircraft such as a
Cessna or a Piper. When petitioner left the service it was
difficult to secure employment as a pilot because the number of
pilots exceeded the number of positions available. As a result,
petitioner sought to increase his FAA fixed-wing rating through
more classes and flight time. On March 16, 1992, petitioner
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