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LEE v. C.I.R.

No. 81-7845.

723 F.2d 1424 (1984)

Edward C. LEE and Mary C. Lee, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided January 17, 1984.

Attorney(s) appearing for the Case

Gary James Joslin, Salt Lake City, Utah, for petitioner-appellant.

Glenn L. Archer, Jr., Michael L. Paup, Robert T. Duffy, Philip Brennan, Washington, D.C., Richard J. Shipley, Seattle, Wash., M. Carr Ferguson, Washington, D.C., for respondent-appellee.

Before WRIGHT, TANG, and ALARCON, Circuit Judges.

EUGENE A. WRIGHT, Circuit Judge:

In this appeal we consider whether the Tax Court held correctly that Edward Lee's educational expenses were not deductible under I.R.C. § 162. We agree with the Tax Court's conclusion that helicopter flight training was not required to maintain or improve the skills required in Lee's employment as a commercial airline pilot.

I

FACTS

Lee, a commercial pilot for Delta Airlines, incurred educational expenses...

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