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We have no doubt that the courses petitioner took greatly
improved his skills in being a pastor, and that petitioner
intends to continue with the UMC. Unfortunately, we apply an
objective test in determining whether a course qualifies a
taxpayer for a new trade or business, Diaz v. Commissioner,
supra, and the courses taken by petitioner prepared him for
positions outside the ministry. See Meredith v. Commissioner,
T.C. Memo. 1993-250. We conclude that petitioner is not entitled
to a deduction for his educational expenses because the courses
qualified petitioner in a new trade or business.
In reaching our holding herein, we have considered all
arguments made, and to the extent not mentioned above, we
conclude them to be moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011