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Spring Industries is a manufacturer of home furnishings.
Petitioner was hired into the "General Management Program"
(program). Candidates for the Spring Industries program were
required to have an M.B.A. or equivalent. As described by Spring
Industries, the program "is a proving ground for future top
executives" and "prepares associates for careers in marketing,
finance or operations management." When petitioner completed the
program with Spring Industries, she became an "associate brand
manager".
On their joint Form 1040, U.S. Individual Income Tax Return,
for 1998, petitioners deducted on Schedule A $20,317 for
"REQUIRED EDUCATION" (having reduced $21,125 by $808, 2 percent
of reported adjusted gross income).
Discussion
The Court decides this case on the preponderance of the
evidence, regardless of the allocation of the burden of proof.
Section 74911 is therefore inoperative.
Petitioner argues that she was employed as an "investment
banker" with the M-L and James companies, having the job title
"financial analyst". She did not abandon her trade or business
as an "investment banker" by attending Kellogg for 2 years, she
1Sec. 7491 is effective with respect to court proceedings
arising in connection with examinations by the Commissioner
commencing after July 22, 1998, the date of its enactment by sec.
3001(a) of the Internal Revenue Service Restructuring and Reform
Act of 1998, Pub. L. 105-206, 112 Stat. 726.
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