Key legal question
Whether EMBA expenses qualify as deductible continuing education costs rather than non-deductible career advancement costs.
Extracted holding
The EMBA expenses were deductible as continuing education because the taxpayer kept his job, received no salary increase, and the EMBA was linked to his engineering background.
Extracted reasoning
Deductibility depends on whether the expenses are objectively connected to current professional activity and serve to maintain or secure the taxpayer's professional position. Here, the EMBA deepened business knowledge already related to the mechanical engineering background and did not primarily serve a new professional advancement.