- 10 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: March 27, 2008