Will M. McEuen III and Tracy L. McEuen - Page 10

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          intend to enter the new field of endeavor, and even though the              
          taxpayer's duties are not significantly different after the                 
          education from what they had been before the education.  Kersey             
          v. Commissioner, T.C. Memo. 1993-641, affd. without published               
          opinion 50 F.3d 15 (9th Cir. 1995); sec. 1.162-5(b)(1), Income              
          Tax Regs.                                                                   
               If the education qualifies the taxpayer to perform                     
          significantly different tasks and activities than could be                  
          performed before the education, the education qualifies the                 
          taxpayer for a new trade or business.  Glenn v. Commissioner, 62            
          T.C. 270, 275 (1974); Weiszmann v. Commissioner, 52 T.C. 1106,              
          1110 (1969), affd. per curiam 443 F.2d 29 (9th Cir. 1971).                  
          Therefore, if petitioner's master's degree qualified her to                 
          perform significantly different tasks and activities than she               
          performed before the education, the education qualified                     
          petitioner for a new trade or business.                                     
               After petitioner obtained her master's degree in management,           
          she did not obtain a position with an investment banking firm.              
          Petitioner was hired by Spring Industries, a manufacturer of home           
          furnishings, into its "General Management Program".  A                      
          prerequisite to being hired under the program was an M.B.A. or              
          equivalent.  The purpose of the general management program was to           
          train future executives and prepare them for careers in                     
          marketing, finance, or operations management.                               






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