NELSON, Circuit Judge:
Manocchio (taxpayer) appeals from the Tax Court's decision to deny in part his deduction of the cost of a flight training course as a business expense. Ninety percent of the expense of the course had been reimbursed under a veterans' benefit program. The Tax Court held that the reimbursed portion of the expense was not deductible, that a prior revenue ruling and I.R.S. publication to the contrary did not estop the I.R.S. from retroactively denying...
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