- 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 (continued...)Page: 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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