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Petitioner performed many of these same functions before he
earned his MBA. Petitioner remained a full-time employee of
Selane Products while in the MBA program.
Petitioner deducted his MBA-related expenses on his Schedule
A, Itemized Deductions, on Form 2016-EZ, Unreimbursed Employee
Business Expenses, which he timely filed along with his
electronic Federal income tax return for 2001. Petitioner also
incurred substantial business expenses traveling for Selane
Products that he deducted on his Schedule A.
Specifically, petitioner deducted $17,5009 of tuition
expenses and $231 of parking fees associated with his education.
In addition, petitioner deducted business-related expenses of
$104 in vehicle expenses, $1,091 in travel expenses, and $113 in
meal expenses. Petitioner also deducted $40 of tax preparation
fees on his Schedule A.
Respondent disallowed petitioner’s deductions and mailed him
a deficiency notice on October 1, 2003. In the notice,
respondent determined a $4,872 deficiency and $974 accuracy-
related penalty under section 6662(a) for 2001. Petitioner filed
a timely petition.
8(...continued)
management department in the position of “Sales/Marketing.”
9See infra note 15.
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