Ronald Z. Thompson - Page 4

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          employers or by any law or regulation.  Petitioner was not                  
          reimbursed for the expenses paid to attend Sierra Academy.                  
               In 2002, petitioner paid Sierra Academy $17,826 for tuition            
          and $929 for required books, equipment, and uniforms.  He                   
          reported $18,755 as educational expenses on his Schedule A,                 
          Itemized Deductions, for 2002.  Petitioner prepared his 2002                
          Federal income tax return using tax preparation software.                   
               On November 15, 2005, respondent mailed petitioner the                 
          notice of deficiency with respect to 2002 which denied                      
          petitioner’s deductions for educational expenses.  Petitioner               
          timely filed his petition on December 22, 2005.                             
               Section 162(a) allows a deduction for all ordinary and                 
          necessary expenses paid or incurred during the taxable year in              
          carrying on any trade or business.  Generally, expenditures made            
          by an individual for education are deductible under section                 
          162(a) if the education maintains or improves skills required of            
          the individual in his employment or other trade or business or              
          meets the express requirements of the individual’s employer.                
          Sec. 1.162-5(a), Income Tax Regs.  However, even if the general             
          rule is satisfied, expenses for education are nondeductible if              
          the education is part of a program of study which will lead to              
          qualifying an individual for a new trade or business.  Sec.                 
          1.162-5(b)(1), (3), Income Tax Regs.                                        

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