- 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 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 “willPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011