- 8 -
Commissioner, 269 F.2d 108 (4th Cir. 1959).
We next address whether petitioners may deduct expenses
relating to Mrs. Garcia’s European travels. Mrs. Garcia claims
that her experiences during her travels gave her new insights
into some of the topics she taught in her English class. She
only deducted the costs of her travels to places she argues were
relevant to classroom material.
No deduction is allowable for expenses for travel as a form
of education. Sec. 274(m)(2). Moreover, expenditures by a
taxpayer for education are deductible only if the education
maintains or improves skills required in the individual’s
employment, or the education meets the express requirements of
the individual’s employer imposed as a condition of employment.
Sec. 1.162-5(a), Income Tax Regs. The taxpayer must establish
that there is a direct relationship between the costs incurred
and the skills required in his or her employment. Jorgensen v.
Commissioner, T.C. Memo. 2000-138. See Carroll v. Commissioner,
supra (simply because the education is helpful in the performance
of the taxpayer’s employment does not establish that its cost is
deductible). While we recognize that Mrs. Garcia may have gained
insights during her travels that were helpful to her role as a
high school English teacher, she has not established a direct
relationship between her travels and the specific skills required
of her as a high school English teacher. Nor has she shown that
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011