- 5 - maintains or improves skills required by the taxpayer in his employment, or (2) meets the express requirements of the taxpayer’s employer, or of applicable law or regulations, imposed as a condition to the retention by the taxpayer of an established employment relationship, status, or rate or compensation. Sec. 1.162-5(a), Income Tax Regs. However, expenses which fall into either of these categories are nevertheless not deductible if the education (1) is required in order to meet the minimum educational requirements for qualification in the taxpayer’s employment, or (2) qualifies the taxpayer for a new trade or business. Sec. 1.162-5(b), Income Tax Regs. The first category of deductible expenses is for education which maintains or improves skills required by the taxpayer in his employment. Sec. 1.162-5(a)(1), Income Tax Regs. The regulations state that this category of expenses “includes refresher courses or courses dealing with current developments as well as academic or vocational courses”. Sec. 1.162-5(c)(1), Income Tax Regs. We find that the M.B.A. program did not serve to maintain or improve skills required in petitioner’s employment within the meaning of the regulations. The courses which petitioner completed as part of the M.B.A. program were varied and encompassed a large number of business fields: The courses covered areas including economics, management, finance, accounting, technology and computer networks, marketing,Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011