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In an amended answer, respondent claimed an increased
deficiency of $1,344, for a total deficiency of $3,159 for the
taxable year 1997.
After a concession by respondent, the sole issue we must
decide is whether petitioners are entitled to deduct legal
educational expenses incurred by petitioner Sara Galligan in
obtaining her law degree.
Some of the facts have been stipulated and are so found.
Petitioners resided in Eagan, Minnesota, at the time they filed
their petition.
Petitioner Sara Galligan (Mrs. Galligan) has been an
academic and court law librarian for 25 years. Mrs. Galligan has
held a variety of law librarian positions as a State Court
employee for 15 years. She is currently the Dakota County Law
Library Manager (Law Library Manager). As the Law Library
Manager, Mrs. Galligan’s primary duties consist of legal
research, overall management and administration of the law
library, and support on an on-going basis to attorneys, judges,
and other individuals using the Dakota County Law Library. She
was president of the Minnesota Association of Law Librarians from
1999 to 2000.
Mrs. Galligan attended William Mitchell Law School from
August 1994 through December 1998 and received her law degree.
While she attended law school, Mrs. Galligan worked full-time for
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