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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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