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deduction under section 221.1 Petitioner resided in New York,
New York, at the time the petition was filed.
Background
Educational Expenses and Article 21 Exemption
Petitioner is a citizen of Belgium. In June of 1997,
petitioner graduated from Katholieke Universiteit Leuven in
Belgium, where he earned a law degree. After graduation and
until the following August, petitioner worked as a legal
assistant for his father, a Belgian attorney. Petitioner was not
admitted to the Belgian bar. In Belgium, a law school graduate
must work for 3 years as a “studiare” or apprentice before
qualifying for admission to the bar.
In August of 1997, petitioner came to New York City to
attend Columbia University School of Law (Columbia). In May of
1998, he was awarded a Master of Laws (LL.M.) in Corporate
Finance. In July of 1998, petitioner sat for and passed the New
York State bar examination.
Petitioner desired to work temporarily as an attorney in New
York City. He was advised to obtain a J.D. degree to increase
his marketability in the competitive New York City legal
community. Petitioner enrolled in the J.D. program at Columbia
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the year in issue, and
Rule references are to the Tax Court Rules of Practice and
Procedure.
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