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practice of law if she should choose. Unlike the taxpayer in
Beatty, Mrs. Galligan’s pursuit of a law degree qualified her for
the practice of law. Thus, Mrs. Galligan’s law school education
was part of a program which qualified her for a new trade or
business. Accordingly, we sustain respondent’s determination
that Mrs. Galligan’s legal education expenses are not deductible.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011