Hart v. Comr., T.C. Memo. 2013-289

(petitioner not allowed to deduct  costs associated with obtaining MBA degree under I.R.C. Sec. 162(a); petitioner graduated from college in 2007 and enrolled in MBA program in 2009; petitioner had various employers in 2009, none of which required him to obtain MBA; petitioner not in established trade or business before enrolling in MBA program, thus expenses not deductible; while petitioner qualified to engage in trade or business of selling pharmaceutical products, petitioner did not actually carry-on such business before enrolling in MBA program).