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Petitioner did not provide any materials as evidence of the
specific content of the English and advanced placement courses he
taught or the Worcester courses. We find that petitioners have
failed to demonstrate a connection between petitioner’s
attendance at the Worcester courses and his job as a high school
English teacher. See Takahashi v. Commissioner, 87 T.C. 126
(1986) (taxpayers failed to demonstrate a connection between
their attendance at a seminar in Hawaii on “Hawaiian Cultural
Transition in a Diverse Society” and their jobs as science
teachers). Thus, we conclude petitioner has failed to prove that
the Worcester courses had a direct and proximate relationship to
maintaining or improving his skills as a high school English and
advanced placement teacher.
Since petitioner has failed to demonstrate that the
Worcester courses had a direct and proximate relationship to
maintaining or improving his skills as a high school English and
advanced placement teacher, we need not determine whether the
expenses incurred by petitioner in attending the Worcester
courses were “ordinary and necessary” within the meaning of
section 162(a).
Therefore, we disallow for lack of substantiation the
claimed miscellaneous deductions of $33,785 for job expenses
incurred during taxable year 1999.
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