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Thanks for all the details. I've never really known what the merchant marines was and just figured it had something to do with the U.S. Marine Corps. I just read a synopsis on it on Wikipedia and see that its somewhat between the U.S. Coast Guard and the Navy, as a merchant marine can be commissioned into the navy as a navy officer. I found the reading interesting.

Basically, what you're seeking is clarity on just what qualifies as a qualified education expense. The IRS is quite clear on this really, defining qualified expenses as tuition, books, and lab fees. There are no exceptions to that either. While what qualifies as tuition and lab fees is pretty straightforward, the category of "lab fees" is rather broad. For example, in the last few years the IRS has updated lab fees to include the cost of a computer for the student provided two basic criteria are met, and the criteria are not really that clear. But here's how I interpret them.

Now, based on your explanation of the maintenance fee for the boat combined with my understanding of this "grey area" concerning unqualified but allowed expenses paid "in support" of the education, I would feel safe claiming that fee as a 529 expense, just as I would claim room and board. Here's my take on this. You say:

 "We had to pay for something called a “Ship maintenance fee” as a part of his college fees."

So if your son was living in the campus dormitory you'd be paying rent for that too, right? That rent would include the cost of keeping the common areas cleaned, bathrooms cleaned, etc. So I see that ship maintenance fee as a part of the "rent" being paid to live on the ship while deployed on the water for training. It does, without question, meet the IRS requirement of that payment being a "condition of enrollment" in order for him to "attend class" on the ship.

Ya know, this is one of those that I would absolutely *LOVE* to see in federal tax court. But I would be to unsure of the outcome to bet any money on either side.

 1) If any class requires the submission of class assignments (such as homework) electronically, and;

 2) The school does not offer reasonable access to the resources necessary for the student to meet the requirement.

I say the above is vague, because the IRS does not define "reasonable access". But most colleges have a 24/7 accessible lab or computer room that students can use at any time.  But if there's not enough computers, does that mean the school does not offer "reasonable access"? It's one of those grey areas.  Enough of this on the qualified education expenses.

You mention that you have 529 funds in this game. So let me clarify a bit more on this deductible education expenses stuff. There are basically three categories or sources of income that are used to pay for one's education, and not just the "qualified" expenses either.

 - Scholarships/Grants -- These income sources are applied  first by the IRS to qualified education expenses. Scholarships and grants can only be used to pay for tuition, books and lab fees. That's it with no exceptions.

QTP/529/Coverdell Funds -- These income sources are applied second by the IRS for the qualified education expenses of tuition, books, and lab fees. Additionally, these funds can also be used to pay for the unqualified but allowed expenses of room and board, *provided* that room and board was paid for in direct support of the education. For example, say the student was living away from home in Maryland for the entire year, attending college in 2018.  They enrolled/attended classes for the  2018 Fall semester Jan - May, then remained in Maryland for the summer semester Jun-Aug but did NOT enroll in or attend any classes, then attended the spring semester Sept - Dec 2018. IN this scenario all room and board for the summer months would not be deductible because the student was not enrolled in/did not attend classes June through August. So room and board paid for those months was not in any way, "in direct support" of the education.

Out of Pocket Expenses -- The only qualified out of pocket expenses are the same as they are for scholarships and grants. Tuition, books and lab fees. Room and Board is *not* a qualified out of pocket expense.