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Respondent determined a deficiency in petitioner’s Federal
income tax of $6,437 for the taxable year 2000.
The issue for decision is whether petitioner is entitled to
deduct as trade or business expenses various costs he incurred in
connection with a Master of Business Administration (M.B.A.)
degree program.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in New
York, New York, on the date the petition was filed in this case.
Petitioner has earned a bachelor’s degree in engineering, a
bachelor’s degree in economics, and a master’s degree in social
science and international trade. From January 1997 through June
1999, petitioner was with the Beijing, China, office of Andersen
Consulting, working as a consultant in the strategic services
group. In this position, he helped foreign companies develop
joint venture strategies and financial structures for operations
in China; he advised foreign companies on Chinese tax policies;
and he helped companies develop marketing strategies for sales in
China.
In Fall 1999, petitioner commenced studies as a full-time
student in the M.B.A. degree program at the Massachusetts
Institute of Technology, Sloan School of Management (MIT).
During the year in issue, petitioner continued as a full-time
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