Roger Steven Lewis - Page 8




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          MBA studies but actually spent $20,000.  No evidence was offered            
          to substantiate these amounts.                                              
               Section 162 and the regulations thereunder generally allow a           
          deduction for ordinary and necessary business expenses, including           
          expenses of education, which (1) maintain or improve skills                 
          required by an individual in his employment or other trade or               
          business, or (2) meet the express requirements of the                       
          individual's employer, or the requirements of applicable law or             
          regulations, imposed as a condition to the retention by the                 
          individual of an established employment relationship, status, or            
          rate of compensation.  Sec. 1.162-5(a), Income Tax Regs.                    
          However, section 1.162-5(b), Income Tax Regs., describes certain            
          educational expenditures that are not deductible as ordinary and            
          necessary business expenses even though the education may                   
          maintain or improve skills required by the individual in his                
          employment or may meet the express requirements of the                      
          individual's employer or of applicable law or regulations.  As              
          applicable here, such expenditures include those "made by an                
          individual for education which is part of a program of study                
          being pursued by him which will lead to qualifying him in a new             
          trade or business."  Sec. 1.162-5(b)(3), Income Tax Regs.                   
               Under section 1.162-5(b)(3), Income Tax Regs., if a taxpayer           
          is pursuing a course of educational study which qualifies the               
          taxpayer for a new trade or business, the expenditures are not              





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