Kernrechtsfrage
Whether MBA study costs are deductible as professional training expenses under direct federal tax law.
Extrahierter Entscheid
The MBA costs were not deductible because the program constituted non-deductible education leading to substantial additional qualifications and better career prospects, not mere maintenance or updating of existing skills.
Extrahierte Begründung
The Court emphasized the substantial total expense, the gap between the taxpayer's original banking apprenticeship and the university-level MBA program, the broader and more advanced content of the program, its English/international orientation, and the fact that employer support did not convert it into mere continuing education.