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satisfied by a showing that the taxpayer did not in fact carry on
or did not intend to carry on a new trade or business. Burnstein
v. Commissioner, 66 T.C. 492, 495 (1976).
Respondent argues that the courses taken by petitioner
qualify him for a new trade or business, and that the expenses of
a college education are almost always nondeductible personal
expenses.
We conclude that the courses, which ultimately led to
petitioner’s bachelor’s degree, qualified petitioner in a new
trade or business. The courses taken by petitioner provided him
with a background in a variety of social issues that could have
prepared him for employment with several public agencies and
private non-profit organizations outside of the ministry.
Whether or not petitioner remains in the ministry is irrelevant;
what is important under the regulations is that the degree “will
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Last modified: May 25, 2011