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Whether education maintains or improves skills required by
the taxpayer’s employment is a question of fact. See Boser v.
Commissioner, 77 T.C. 1124, 1131; Schwartz v. Commissioner, 69
T.C. 877, 889 (1978); Baker v. Commissioner, 51 T.C. 243, 247
(1968). The burden of proof is on the taxpayer. See Rule
142(a); Welch v. Helvering, supra; Boser v. Commissioner, supra
at 1131; cf. sec. 7491. The fact that petitioner’s education is
helpful to him in the performance of his employment does not
establish that its cost is deductible as a business expense. See
Carroll v. Commissioner, 51 T.C. 213, 215 (1968), affd. 418 F.2d
91 (7th Cir. 1969). Petitioner must establish that there is a
direct and proximate relationship between the Worcester courses
and the skills required in his employment as a high school
English teacher. See Kornhauser v. United States, 276 U.S. 145,
153 (1928); Boser v. Commissioner, supra at 1131. A precise
correlation is not necessary, but the expenditure must enhance
existing employment skills. See Boser v. Commissioner, supra.
Petitioner’s employer did not expressly require him to take the
courses at issue. We therefore assess whether the Worcester
College courses attended by petitioner maintained or improved his
skills as a high school English teacher. See sec. 1.162-5(a),
Income Tax Regs.
Petitioner has not provided specific examples of how his
teaching skills were enhanced by the Worcester courses.
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