This section contains the nature of the case and procedural background.

P decided to pursue a career in the ministry of the United Methodist Church (UMC). The rules for each level of candidacy can be found in the UMC's 1992 Book of Discipline. The levels, in ascending order, are: (1) Certified candidate, (2) local pastor, (3) associate member, (4) probationary member, and (5) member in full connection. Each level had specific educational requirements. P will be unable to become a member in full connection because of the time commitment, as P will be forced to retire at the age of 70. From 1993 to 1996, P was a part-time local pastor. In 1992, P became a certified candidate. Prior to entering the candidacy for ministry, P accumulated over 60 undergraduate semester hours from various schools, which met the minimum undergraduate educational requirements to become an associate member. P wanted to improve his ministry skills. These included interpersonal skills, relational skills (e.g., working with situations in which parishioners could be involved), sermon writing skills, leadership skills, and management skills. P decided to take courses at the University of Great Falls. These courses were not required for P to continue as a local pastor. P earned a bachelor's degree in human services. P claimed a deduction of $9,698 for 'Continuing Education' on their Schedule C, Profit or Loss From Business. D was upset and disallowed the deduction. D claimed that P had not established that the business expense shown was paid or incurred during the taxable year and that the expense was ordinary and necessary to P's business. P petitioned the Tax Court.

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