- 14 - Petitioner’s business after enrolling in the MBA program did not significantly change. After completing the MBA program, petitioner established with testimony that his business involved the same general activities that he performed before enrolling in the program, activities involving sales, marketing, and management. While petitioner was awarded with new positions and titles after he enrolled in the program and while the MBA may have sped his advancement within Selane Products, the basic nature of his duties did not significantly change. The MBA rather improved preexisting skills that petitioner used before enrolling in the MBA program. We also distinguish our facts from cases involving taxpayers embarking on a course of study that qualified them for a professional certification or license. Courts considering those factors have often found that the education expenses were not deductible, even where the taxpayer performed many of the same activities before the education. For instance, the Court denied taxpayers’ deduction for law school expenses on four occasions because law was a field of study that led the taxpayers to qualify for the new trade or business of being an attorney. See Bodley v. Commissioner, 56 T.C. 1357 (1971); Weiler v. Commissioner, supra; Weiszmann v. Commissioner, supra at 1110- 1111; Galligan v. Commissioner, T.C. Memo. 2002-150, affd. 61Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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