George W. Warren and Florence J. Winterheld - Page 7

                                        - 7 -                                         
          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                
               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            

Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011