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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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Last modified: March 27, 2008