Veronica L. Foster - Page 11




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               The Court accepts petitioner’s contention that the M.B.A.               
          improved her project management skills.  By taking management                
          courses, she likely improved her ability to design and supervise             
          operations, teams, and projects.  Accounting and finance courses             
          likely improved her ability to manage budgets and to project                 
          costs.  We note, however, that the HBS requirement that                      
          petitioner study accounting and finance before matriculation                 
          indicates that HBS demanded greater mastery of these areas (not              
          only greater than petitioner possessed before the M.B.A. but also            
          greater than her job as an engineer required).  Undoubtedly,                 
          petitioner gained even greater mastery while at HBS.                         
               As part of her M.B.A. curriculum, petitioner extensively                
          studied marketing, an area her engineering studies did not                   
          cover.6  “An individual who, through education, improves * * *               
          [her] skills in an existing trade or business may also become                
          qualified for a new trade or business.”  Thompson v.                         
          Commissioner, T.C. Memo. 2007-174.  In Thompson, an aeronautical             
          engineer’s flight and pilot lessons improved his skills as an                
          engineer but also qualified him for a new trade or business as a             
          pilot and, therefore, were not deductible.                                   
               Before the M.B.A., petitioner worked in New Zealand as an               
          engineer.  While pursuing the M.B.A., she worked for Snapple in              

               6 In addition to one required marketing course and three                
          required courses in finance and financial reporting, petitioner              
          took three marketing electives and one finance elective.                     





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