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deductible even though the studies are required by the employer,
and the taxpayer does not intend to enter a new field of
endeavor, or even though the taxpayer's duties are not
significantly different after the education from what they had
been before the education. Robinson v. Commissioner, 78 T.C.
550, 556-557 (1982); Bodley v. Commissioner, 56 T.C. 1357, 1360
(1971); Schwerm v. Commissioner, T.C. Memo. 1986-16.
Respondent has not questioned, nor does there appear to be
any doubt, that the educational expenses maintained or improved
petitioner's skills in his trade or business, and that the
education was not necessary to meet the minimum requirements of
the position he held with his employer. The question of whether
an educational expenditure qualifies a taxpayer for a new trade
or business requires a "commonsense approach". Reisinger v.
Commissioner, 71 T.C. 568, 574 (1979). "If the education
qualifies the taxpayer to perform significantly different tasks
and activities than he or she could perform prior to the
education, then the education qualifies him or her for a new
trade or business." Browne v. Commissioner, 73 T.C. 723, 726
(1980) (citing Diaz v. Commissioner, 70 T.C. 1067, 1074 (1978),
affd. without published opinion 607 F.2d 995 (2d Cir. 1979));
Glenn v. Commissioner, 62 T.C. 270, 275 (1974).
Thus, even if a taxpayer does not intend to enter into a new
field of endeavor, or even if the taxpayer's duties are not
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