Alex Kopaigora (plaintiff) worked for Marriott International Corporation as an established finance and accounting business manager. In July 2010, Kopaigora enrolled in a weekend EMBA program. Kopaigora took classes that included Introduction to Management, Corporate Financial Reporting, and Human Resources Management. In April 2011, Marriott fired Kopaigora. Kopaigora continued to attend classes, while also searching for a full-time job in the corporate finance and accounting industry. In August 2012, Kopaigora graduated with his EMBA. In September 2012, Driveit Financial Services hired Kopaigora as Vice President of Finance. On his federal income tax return, Kopaigora claimed a deduction for his education expenses. The Internal Revenue Service (IRS) (defendant) determined that the expenses were not deductible. Kopaigora appealed.