Key legal question
Whether repayment of police school costs is deductible as professional further training expenses or non-deductible education costs.
Extracted holding
The police school repayment was non-deductible education cost, not further training expense, because it qualified the taxpayer for a new and essentially different profession.
Extracted reasoning
Further training deductions cover only costs incurred within an already learned and practiced profession. The police school was a full-time course for entering a new occupational field; the taxpayer did not improve skills for his prior commercial or military-police work.