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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. 61
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