Question juridique clé
Whether the costs of the part-time program at the Higher School of Economics qualify as deductible continuing-education expenses rather than nondeductible training expenses.
Solution extraite
The business-school course was deductible because it built on the taxpayer's commercial apprenticeship and served to deepen and extend knowledge for her existing bookkeeping work, not to enable a clearly new profession or higher executive position.
Motifs extraits
The court distinguished training from continuing education by asking whether the expenditure serves to acquire an essential new professional qualification or merely to improve the current occupation. Here, the taxpayer remained in bookkeeping and accounting-related functions after the course, so the program expanded her existing professional skills.