- 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011