Carrie Hopkins is a qualified teacher in the San FranciscoUnified School District.
Currently, she teaches at North Lincoln High School where she isalso head of the
English Department. North Lincoln is a culturally diverse schoolwith a predominantly
Asian student population. As a department head, Carrie hasconsiderable input on
curriculum content of the courses offered by her school.
During the summer of 2014, Carrie enrolled in a course sponsoredby the University of
California, Berkeley Extension Program. The course, entitledâSoutheast Asia: Sacred
Places,â was conducted in Thailand, Cambodia, and Indonesia anddealt with the effect of
religious traditions on the culture of Southeast Asia. Thecourse was taught by university
staff, and successful completion by a student qualified forundergraduate college credit.
The course is conducted overseas to enhance the significance ofthe subject matter
covered. Although Carrieâs employer approved of her academicendeavors, it did not
require her to take the course. Further, it did not reimburseher for any of the expenses
involved. Except for several minor sightseeing trips, Carriedevoted 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, Carriemade various
improvements to the content of her departmentâs curriculum. Shealso feels that the
course increased her ability to understand and communicate withthe Asian studentsâ in
her classes.
On her Federal income tax return for 2014, Carrie dedicated allof 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
Carrie Hopkins is a qualified teacher in the San FranciscoUnified School District.
Currently, she teaches at North Lincoln High School where she isalso head of the
English Department. North Lincoln is a culturally diverse schoolwith a predominantly
Asian student population. As a department head, Carrie hasconsiderable input on
curriculum content of the courses offered by her school.
During the summer of 2014, Carrie enrolled in a course sponsoredby the University of
California, Berkeley Extension Program. The course, entitledâSoutheast Asia: Sacred
Places,â was conducted in Thailand, Cambodia, and Indonesia anddealt with the effect of
religious traditions on the culture of Southeast Asia. Thecourse was taught by university
staff, and successful completion by a student qualified forundergraduate college credit.
The course is conducted overseas to enhance the significance ofthe subject matter
covered. Although Carrieâs employer approved of her academicendeavors, it did not
require her to take the course. Further, it did not reimburseher for any of the expenses
involved. Except for several minor sightseeing trips, Carriedevoted 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, Carriemade various
improvements to the content of her departmentâs curriculum. Shealso feels that the
course increased her ability to understand and communicate withthe Asian studentsâ in
her classes.
On her Federal income tax return for 2014, Carrie dedicated allof 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