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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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