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marketing. After the M.B.A., she joined Refreshment Brands as
its new vice president of marketing. Because petitioner has not
demonstrated that she was qualified to work in marketing before
she began studying at HBS, we find that the M.B.A. qualified her
for a new trade or business.
Petitioner’s counsel relies on three cases he asserts
buttress petitioner’s position. In Glenn v. Commissioner, 62
T.C. 270 (1974), we held that a public accountant could not
deduct expenses incurred preparing for and taking a certified
public accountant examination because certified public
accountants are in a different trade or business from public
accountants, on the basis of an analysis of the tasks and
activities they are qualified to perform. This case is not
helpful to petitioner because, while she may be better qualified
with the M.B.A. to work as a project manager for an engineering
consulting company, she is also qualified to perform myriad
business, management, finance, and marketing tasks she was not
qualified to perform before receiving her M.B.A.
In Sherman v. Commissioner, T.C. Memo. 1977-301, we held
that the taxpayer had established that he was engaged in business
administration before going to HBS and that he stayed in that
field after graduation. The taxpayer in Sherman, like
petitioner, needed neither a leave of absence nor the intention
to return to the same position. Unlike the taxpayer in Sherman,
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