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educational expenses were nondeductible. Weiler v. Commissioner,
supra at 402.
Petitioners contend that Mrs. Galligan obtained her law
degree to maintain and improve her skills as a law librarian.
Mrs. Galligan testified that knowledge of the law is both
necessary and helpful in her duties as a law librarian.
Petitioners also argue that Mrs. Galligan did not practice as an
attorney and is, in fact, “not allowed to practice law according
to the tenets of [her] profession.”
Petitioners rely on Beatty v. Commissioner, T.C. Memo. 1980-
196, which we find distinguishable. In Beatty, the Court held
that a taxpayer was allowed to deduct the educational expenses
associated with the pursuit of a Masters of Science degree in
Administration. In that case, the Court held that the studies
provided the taxpayer with a broad general background in
management and business administration, activities which were
already components of the taxpayer’s work activities. Id.
Unlike the instant case, the Court noted that the taxpayer’s
education did not qualify him for a new trade or business. Id.
We do not dispute that Mrs. Galligan was an outstanding law
librarian and that the legal education was helpful in her
profession as a law librarian. However, by attending law school
and obtaining her law degree, Mrs. Galligan became entitled to
seek admission to the bar, as she did, and to enter the general
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