George W. Warren and Florence J. Winterheld - Page 9

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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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