Galligan v. Commissioner T.C. Memo

2002-150 (2002)

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Nature of the Case

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Facts

P has been an academic and court law librarian for 25 years. She has held a variety of law librarian positions as a State Court employee for 15 years. She is currently the Dakota County Law Library Manager (Law Library Manager). P's primary duties consist of legal research, overall management and administration of the law library, and support on an ongoing basis to attorneys, judges, and other individuals using the Dakota County Law Library. P attended William Mitchell Law School from August 1994 through December 1998 and received her law degree. P worked full-time for the Minnesota State law library. She was admitted to the bar in Minnesota on May 7, 1999. P's employer did not require her to obtain a law degree or attend law school. The requirements were a '[law degree] or at least two years of professional experience in a law library is strongly preferred.' P claimed deductions of $13,313 and $ 14,998, respectively, for P's legal educational expenses. This sent D into a rage for her audacity. D disallowed the expenses. P contends legal educational expenses improved and maintained her skills as a law librarian. D contends the expenses led to her qualification for a new trade or business.