Kopaigora v. Commissioner Tax Court

2016-35 (2016)

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Nature of the Case

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Facts

In 2002, Kopaigora (P) worked as an accounting manager. In June 2006, P was promoted to senior assistant controller. P was responsible for managing a team of employees, reviewing employee performances annually, participating in hiring activities, and training employees. P prepared financial reports, creating budgets, analyzing financial data, produced forecasts to enable reaction to business changes, and monitored different departments' performances. P conducted audits, prepared an accounting of taxes, prepared financial reports according to generally accepted accounting principles, enforced internal controls, reconciled balance sheets, and ensured compliance with reporting requirements. In July 2010, P enrolled in a EMBA degree program at BYU to improve his leadership skills in corporate finance and management. P took a lot of management courses. On April 18, 2011, P's employment was terminated for reasons that were later found to be unjustified. P continued to pursue his EMBA degree and look for full-time employment within the corporate finance and accounting field as a controller, assistant controller, senior manager, vice president, or director. P graduated in August 2012. On September 2, 2012, P was hired as vice president of finance. P was responsible for overseeing department managers, managing and leading a team of employees, supervising employees in daily issues of accounting, cash, risk, and business operations, and participating in hiring and training. Additionally, P was responsible for auditing, accounting for taxes, setting up monthly reporting according to GAAP, and enforcing internal controls. In 2011, P claimed an $18,879 deduction for EMBA degree expenses as unreimbursed employee expenses. Commissioner (D) disallowed the expenses, and the matter was brought before tax court.