- 6 - record and relying to some extent on the GE account statement described, concludes that the equivalent 6.6524 shares (one-half of 13.304 shares) petitioner owned on October 26, 1994, had a basis of $50.5625 per share, the amount paid for the stock transaction of January 25, 1995. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930). Therefore, petitioner's basis for the 13.304 shares converted into cash on May 19, 1997, is $336.36 (6.6524 shares at $50.5625 per share). The Court so holds. In his petition and at trial, petitioner claimed he should be allowed an itemized deduction for educational expenses under section 162(a). During 1997, petitioner attended the University of California at Los Angeles (UCLA). He graduated from UCLA with a master's degree in business administration (MBA) in June 1998. Prior to his enrollment at UCLA, petitioner was employed in the telecommunications industry. He realized, as he stated in a written statement offered in evidence, that "I needed additional accounting, financial, and general business administration skills as I was increasingly called upon to negotiate complex contracts with a wide variety of clients." The MBA degree, petitioner felt, would provide him with that expertise. At trial, petitioner agreed that the MBA degree qualified him for "a wider variety of positions", although he did not pursue such positions. The amount claimed by petitioner for his educational expenses is ambiguous. He testified that he borrowed $10,000 to finance hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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