- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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