Minimum Educational Requirements:
1. 1.162-5(b): does not allow deductions for educational expenses that enable the taxpayer to meet the “minimum educational requirements for qualification” in a trade or business. The big difference in allowance and not is—no for “meet,” yes for “maintain.”
2. Wassenaar v. Commissioner (1979): Guy denied a deduction for LLM expenses. Went straight from law school to get the LLM.
a. Couldn’t have been required by his employer – he didn’t have one.
b. Couldn’t have been designed to improve his skills – he’s not a lawyer.
i. contrast this case with Ruehmann v. Commissioner. If you want an LLM, it’s a far better plan to get admitted to the bar and practice for a few years, then go get the LLM.
3. In addition to disallowing a deduction for costs of minimum educational requirements, the Regs. prohibit deduction of expenditures made by an individual for education which would lead to qualifying him in a new trade or business. 1.162-5(b)(3)(i).
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