Legal Opinion

Link v. Commissioner

United States Tax Court

Decided March 17, 1988No. Docket No. 44158-85PublishedCited by 7 opinions

After obtaining an undergraduate degree in operations research, P began employment in his professional area for the summer and then ceased the employment and continued his education seeking a Master of Business Administration degree. P contends that he was qualified for, and established, in a trade or business and that the cost of his graduate education was deductible because it improved and maintained his skills.

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After obtaining an undergraduate degree in operations research, P began employment in his professional area for the summer and then ceased the employment and continued his education seeking a Master of Business Administration degree. P contends that he was qualified for, and established, in a trade or business and that the cost of his graduate education was deductible because it improved and maintained his skills. R contends that petitioner was not established in his trade or business and that the educational costs were not deductible. Held, P is not entitled to deduct the cost of his…

1Opinion of the Court

GERBER, Judge:

Respondent, in a statutory notice of deficiency dated September 18, 1985, determined a deficiency in petitioner’s income tax of $1,383.76 for taxable year 1983. The sole issue for our decision is whether, petitioner should be allowed to deduct expenses incurred to obtain a master’s degree in business administration (MBA).

FINDINGS OF FACT

Petitioner resided in Cincinnnati, Ohio, when the petition was filed in this case. The stipulated facts and exhibits are incorporated herein by this reference.

Petitioner graduated from Cornell University in May 1981 with a bachelor’s degree in…

2Cases cited4 opinions

  1. Nico v. CommissionerUnited States Tax Court · 1977
  2. Linen Thread Co. v. CommissionerUnited States Tax Court · 1950
  3. Severino R. Nico, Jr. And Teresita v. Nico v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1977
  4. Continental Trading, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959

3Cited by7 opinions

  1. Weyts v. Comm'rUnited States Tax Court · 2003
  2. Hudgens v. CommissionerUnited States Tax Court · 1997
  3. Hume v. Comm'rUnited States Tax Court · 2014
  4. Kopaigora v. Comm'rUnited States Tax Court · 2016
  5. Link v. CommissionerUnited States Tax Court · 1988

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