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in August of 1998. Petitioner received 1 year of credit towards
his J.D. graduation requirements from his studies in the LL.M.
program which would have enabled him to graduate in May of 2000.
Petitioner, however, decided to enroll in a joint J.D./M.B.A.
program that extended his studies for 1 more year.
During the summer of 1999, petitioner worked as a summer
associate for the law firm of Kelley Drye & Warren, LLP (Kelley
Drye). In July of 1999, petitioner was formally inducted into
the New York State Bar. The following summer, from approximately
May to August of 2000, petitioner was employed as a summer
associate at the law firm of Davis Polk & Wardwell (Davis Polk).
Petitioner received both monetary compensation from Davis Polk
and 3 hours of class credit.
On his 2000 Federal income tax return, petitioner claimed a
Schedule A itemized deduction of $36,154 for educational
expenses. Upon examination, respondent disallowed the deduction.
Charitable Contribution Deduction
Sometime in 2000, petitioner paid $700 to attend a student
benefit to raise money for an informal organization to allegedly
aid minority student’s scholarships. This amount entitled
petitioner to attend a benefit at which a dinner was served.
Petitioner did not attend the dinner. On his 2000 return,
petitioner did not claim a charitable contribution deduction for
the amount paid. Petitioner now claims that he is entitled to
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