- 5 - An individual who, through education, improves his skills in an existing trade or business may also become qualified for a new trade or business. Educational expenses incurred to qualify for a new trade or business are nondeductible even if the individual does not engage in the new activity. See sec. 1.162-5(b)(3)(ii) Example (2), Income Tax Regs. The mere capacity to engage in a new trade or business is sufficient to disqualify the expenses for the deduction. Weiszmann v. Commissioner, 52 T.C. 1106, 1111 (1969) affd. per curiam 443 F.2d 29 (9th Cir. 1971); see sec. 1.162-5(b)(3), Income Tax Regs. The Court agrees with petitioner’s contention that his training improved his aeronautical engineering skills. By taking flight lessons petitioner likely improved his ability to evaluate cockpit ergonomics and design and troubleshoot future flight concepts. The training also likely improved his skills in testing and evaluating aircraft flight systems software. However, the education undertaken by petitioner was a course of study that led to his receipt of commercial pilot certificates. As a result, this Court must decide whether petitioner became qualified for new trade or business by attaining these certificates. Even though petitioner did not intend to work as a commercial pilot, the commercial pilot certificates qualified him to be employed as a pilot-in-command of an aircraft for singlePage: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007