Key legal question
Whether the postgraduate studies qualify as deductible retraining or continuing education costs for direct federal tax.
Extracted holding
The costs were not deductible retraining or continuing education expenses, but non-deductible education expenses.
Extracted reasoning
The program was a new education aimed at career advancement to a higher position, not preparation for a new occupation caused by a forced occupational change. The deduction for retraining is interpreted narrowly; the taxpayer later returned to work as a construction supervisor and the program had independent educational value.