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telecommunications, “eCommerce”, investments, investment banking,
and mergers and acquisitions. From the record before us, we
conclude that the M.B.A. program in this case served to improve
petitioner’s “general understanding and competency”, Coughlin v.
Commissioner, T.C. Memo. 1969-80, rather than to improve specific
skills required in petitioner’s employment. See, e.g., Menas v.
Commissioner, T.C. Memo. 1969-114 (courses in an M.B.A. program
were not directly related to the skills used by an Internal
Revenue Service agent); Coughlin v. Commissioner, supra, (courses
required for a bachelor’s degree in business administration
provided only an increase in “general understanding and
competency” and did not have a direct relation to the taxpayer’s
employment as a method and controls analyst for an insurance
company). While the M.B.A. program did focus on “business
administration”, it was nonetheless a generalized field of study
which provided an education in a number of areas not necessarily
applicable to petitioner’s employment prior to or after the year
in issue.
Our finding is reinforced by the fact that petitioner was
not employed on a permanent or indefinite basis while he
completed the M.B.A. program. Prior to the program, petitioner
was a consultant for companies doing business in, or interested
in doing business in, China. During the program, petitioner was
employed only in a temporary position in which he earned academic
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