- 15 -
Fed. Appx. 314 (8th Cir. 2003).13 Petitioner’s MBA was not a
course of study leading him to qualify for a professional
certification or license.
We find two cases particularly instructive. On one
occasion, our Court considered whether an MBA degree qualified a
taxpayer for a new trade or business. See Blair v. Commissioner,
T.C. Memo. 1980-488. In that case, the taxpayer was employed as
a personnel manager while taking courses toward an MBA. We found
that the taxpayer was entitled to deduct tuition expenses because
the courses improved the taxpayer’s job skills and did not
qualify the taxpayer for a new trade or business.14 Id.
13Courts have found similarly where the course of study led
taxpayers to qualify for professional certifications. For
instance, the Court has found that a licensed public accountant
is in a different trade or business from a certified public
accountant. See Glenn v. Commissioner, 62 T.C. 270, 275 (1974).
The Court has also found that a pharmacist intern is in a
different trade or business from a registered pharmacist, even
where they each perform many of the same tasks and activities.
See Antzoulatos v. Commissioner, T.C. Memo. 1975-327.
14We denied deductions for MBA expenses in two other cases
on the basis that the taxpayer had not already been established
in a trade or business. See Link v. Commissioner, 90 T.C. 460,
463-464 (1988), affd. 869 F.2d 1491 (6th Cir. 1989); Schneider v.
Commissioner, T.C. Memo. 1983-753; cf. Sherman v. Commissioner,
T.C. Memo. 1977-301. This is distinguishable from our case where
petitioner had worked for Selane Products prior to and throughout
the MBA program. In addition, our facts are distinguishable from
a case in which we denied MBA expense deductions where the
taxpayer’s duties were technical before enrolling in the MBA
program and managerial afterwards. See McIlvoy v. Commissioner,
T.C. Memo. 1979-248; see also Hudgens v. Commissioner, T.C. Memo.
1997-33 (managing assets in a trust company differs significantly
from researching tax issues and preparing tax returns for an
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