George W. Warren and Florence J. Winterheld - Page 4

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               In 1992, petitioner became a certified candidate.  Prior to            
          entering the candidacy for ministry, petitioner accumulated over            
          60 undergraduate semester hours from various schools, which met             
          the minimum undergraduate educational requirements to become an             
          associate member.                                                           
               Petitioner decided that he needed to improve his ministry              
          skills.  Such skills included interpersonal skills, relational              
          skills (e.g., working with situations in which parishioners could           
          be involved), sermon writing skills, leadership skills, and                 
          management skills.  In 1994, petitioner decided to take courses             
          at the University of Great Falls.6  These courses were not                  
          required for petitioner to continue as a local pastor.  In                  
          December 1995, petitioner earned a bachelor’s degree in human               
               On their joint 1994 tax return, petitioners claimed a                  
          deduction of $9,698 for “Continuing Education” on their Schedule            
          C, Profit or Loss From Business.  The amount claimed represented            
          tuition, books, and course-related fees incurred and paid by                
          petitioner for the courses taken at the University of Great                 
          Falls.  In the notice of deficiency, respondent disallowed the              
          deduction, stating:                                                         

               6  Examples of courses taken by petitioner include:                    
          Introduction to Counseling, Internship in Ministry Practice,                
          Death and Dying as a Life Cycle, Modern Social Problems, The                
          Family, Community, Ethics in Human Services, Symphonic Choir,               
          Basic Writing, and Writing Strategies.                                      

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