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Allemeier v. Commissioner
United States Tax Court
90 T.C.M. 197 (2005)
Daniel Allemeier (plaintiff) worked at Selane Products (Selane) in a variety of positions for three years before getting a master’s degree in business administration (MBA). Before enrolling, the CEO of Selane told Allemeier that an MBA would enhance his skills and help him advance at the company. However, Selane did not require Allemeier to get an MBA and did not reimburse him for the cost. While getting his degree, Allemeier continued to work at Selane and was promoted several times during the course of the program. Allemeier deducted the cost of his tuition on his income-tax return as a business expense. The Commissioner of Internal Revenue (the Commissioner) (defendant) disallowed the deduction, arguing that the MBA was both a minimum education requirement for Allemeier’s continued employment at Selane and that the MBA qualified Allemeier for a new trade or business. Either argument would have barred Allemeier from deducting the cost of his MBA. Allemeier disagreed with both characterizations, instead arguing that his continued employment was not dependent on his getting an MBA and that the MBA would give him better background knowledge and improve his skills at work he was already engaged in. Allemeier petitioned the United States Tax Court for a redetermination.
Rule of Law
Holding and Reasoning (Kroupa, J.)
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