Carrie Hopkins is a qualified teacher in the San Francisco Unified School District.

Currently, she teaches at North Lincoln High School where she is also head of the

English Department. North Lincoln is a culturally diverse school with a predominantly

Asian student population. As a department head, Carrie has considerable input on

curriculum content of the courses offered by her school.

During the summer of 2014, Carrie enrolled in a course sponsored by the University of

California, Berkeley Extension Program. The course, entitled Southeast Asia: Sacred

Places, was conducted in Thailand, Cambodia, and Indonesia and dealt with the effect of

religious traditions on the culture of Southeast Asia. The course was taught by university

staff, and successful completion by a student qualified for undergraduate college credit.

The course is conducted overseas to enhance the significance of the subject matter

covered. Although Carries employer approved of her academic endeavors, it did not

require her to take the course. Further, it did not reimburse her for any of the expenses

involved. Except for several minor sightseeing trips, Carrie devoted most of her time

during the course to the materials assigned and covered.

As a result of what she learned from the course she took, Carrie made various

improvements to the content of her departments curriculum. She also feels that the

course increased her ability to understand and communicate with the Asian students in

her classes.

On her Federal income tax return for 2014, Carrie dedicated all of the expenses incurred

in connection with the extension course. Upon audit by the IRS, the deduction is

disallowed. Who should prevail? And why?

Aid:

IRC 162(a) 262(a) and 274(m)(2)

Treasire. Reg. 1.162-5(e)

Takahshi v. Comm., T.C 126 (1986)

Jorgensen v. Comm., 79 TCM 1926, T.C Memo 2000-138