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conditions are satisfied. Sec. 1.162-5(a), Income Tax Regs. The
education must either maintain or improve skills the taxpayer
needs for his or her trade or business, or the education must
meet express requirements set forth by law or regulation or the
taxpayer’s employer as a condition to the taxpayer’s retention of
his or her employment. Id. Even if the education meets one of
these alternatives, there is an exception to the deductibility of
education expenses. Education expenses are not deductible if the
education allows the taxpayer to meet the minimum educational
requirements for his or her job or to qualify the taxpayer for a
new trade or business. Garwood v. Commissioner, 62 T.C. 699
(1974); sec. 1.162-5(b), Income Tax Regs.
Mr. Farran testified that the $461 petitioners claimed
represented mileage expenses incurred when Mr. Farran traveled
from his home in Farmington, Minnesota, to his classes at Dakota
County Technical College. Passenger automobiles are listed
property under section 280F, and strict substantiation is
therefore required. Sec. 274(d). No deduction is allowed for
any travel expense unless the taxpayer corroborates by adequate
records or by sufficient evidence corroborating the taxpayer’s
own statement the amount of the expense, the mileage for each
business use of the automobile and the total mileage for all use
of the automobile during the taxable period, the date of the
business use, and the business purpose for the use. Sec. 1.274-
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Last modified: November 10, 2007