Daniel R. Allemeier, Jr. - Page 16

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          Similarly, in another case before our Court, we held that a                 
          taxpayer was allowed to deduct the educational expenses                     
          associated with a master of science degree in administration                
          where the studies provided the taxpayer with a broad general                
          background in management and business administration, activities            
          that were already components of the taxpayer’s work activities.             
          See Beatty v. Commissioner, T.C. Memo. 1980-196.  As in Blair and           
          Beatty, petitioner’s MBA courses provided him with a general                
          background to perform tasks and activities that he had performed            
          previously at Selane Products.                                              
               We also decline to find as an objective matter that the MBA            
          qualified petitioner in a “new” trade or business, where                    
          petitioner had substantial work experience directly related to              
          his MBA coursework.  See Robinson v. Commissioner, 78 T.C. 550,             
          554-556 (1982); Glenn v. Commissioner, supra at 275; Weiler v.              
          Commissioner, 54 T.C. 398, 401-402 (1970); sec. 1.162-5, Income             
          Tax Regs.  The MBA qualified petitioner to perform the same                 
          general duties he performed before enrolling in the MBA program.            
               Accordingly, we find that petitioner’s MBA did not meet a              
          minimum education requirement of Selane Products.  Nor do we find           
          that the MBA qualified petitioner to perform a new trade or                 




               14(...continued)                                                       
          accounting firm).                                                           




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