Roland E. Lewis, Jr. - Page 8

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               Section 162 generally allows a deduction for expenses which            
          are ordinary and necessary in carrying on a trade or business.              
          Sec. 162(a).  Such expenses may include educational expenses paid           
          in carrying on the trade or business of being an employee.  Sec.            
          1.162-5, Income Tax Regs.  To be deductible, such expenses must             
          be for education which (1) maintains or improves skills required            
          by the taxpayer in his employment or other trade or business, or            
          (2) meets the express requirements of the taxpayer’s employer, or           
          of applicable law or regulations, imposed as a condition to the             
          retention by the taxpayer of an established employment                      
          relationship, status, or rate or compensation.  Sec. 1.162-5(a),            
          Income Tax Regs.   There is nothing in the record which indicates           
          that petitioner’s engineering education fell within one of these            
          two categories:  There is no suggestion that the education                  
          maintained or improved skills which petitioner used in his duties           
          at NSBE--fundraising and handling career fairs--or that it was              
          required in the context of his established employment                       
          relationship, status, or rate of compensation.                              
               Furthermore, expenses which fall into either of the above              
          two categories nevertheless are not deductible if the education             
          (1) is required in order to meet the minimum educational                    
          requirements for qualification in the taxpayer’s employment or              
          other trade or business, or (2) qualifies the taxpayer for a new            
          trade or business.  Sec. 1.162-5(b), Income Tax Regs.  The                  






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