Mr. Hart began an MBA program in 2009, at the time he was employed as a pharmaceutical salesman. During his enrollment in the program, Mr. Hart also held positions as an account manager for ADP Totalsource and an entry-level professional for Walgreen Co., and was unemployed for a portion of the time. On his tax return for 2009, Mr. Hart claimed his MBA tuition of $18,600 as an unreimbursed employee expense on Schedule A. The Tax Court disallowed the deduction for his MBA tuition expense because Mr. Hart was not in a trade or business in 2009 and his employers did not require him to enroll in an MBA program. Judge Kerrigan stated that being qualified to engage in a trade or business is different than "carrying on" a trade or business, and the Section 162 regulations specify that to be a deductible business expense, the taxpayer must already be established in a trade or business. Adam Hart, TC Memo 2013-289 (Tax Ct.).
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