Questão jurídica principal
Whether the training expenses qualified as deductible professional development costs under direct federal tax law.
Decisão extraída
The lower court had not examined all relevant criteria; the case had to be remitted for further fact-finding and a new decision.
Fundamentação extraída
Deductibility depends on the concrete content of the training, the taxpayer’s prior education and career, the value of the diploma on the labor market, and whether the course is merely professional development or a non-deductible formation/advancement program. The record was insufficient.