Business & farm

Appreciate the response, see my continued thought process below to see if it affects your thoughts.  Also I think there is consideration for risk in this scenario too, when claiming this will someone tell you that you are claiming something fraudulently or just disallow the deduction and charge you the penalty and taxes associated with that (generally no harm no foul relatively speaking vs. the potential savings of $4000+ of taxes owed).

Here is some counter food for thought to show you where I was coming from:

"Additionally, while training/education for maintaining or improving existing job skills can be deductible as a business expense, such training/education for new job skills is not. "

See now here is where I get caught up because would one not be able to use exactly that statement as the justification if you once again play devils advocate. Getting a PPL if already having a Part 107 would be improving an existing job skill - I think this could be objectively demonstrated.  Also Topic 513 is referring to self-employed individuals, I am talking about a business taking an expense for an employee's education.  I thought a company could take an expense in order to make available business opportunities (the necessary of ordinary and necessary) as long as its not an entirely new business endeavor.  This business flies UAVs already it just opens up the door to a couple of new large contracts to do exactly what they are now.

I think its the ordinary part of that test that seems subjective - are they going to compare a company with employees(albeit still technically a small business in this case but with multiple employees and significant comparative revenues) to a free-lancer/disregarded entity? The freelancers are likely the bulk of the UAS work being done right now but a freelancer is going to have different interests to a company or even to other freelancers (some may be choosing clients based on flexibility/per diem opportunities, or stability, or proximity to home base, etc), where as engineering firms, such as this, may already have long term customers they service and/or are more customer selective (because they don't hang their hat on UAV work) for high profile customers that want a Professional Engineer and a Part 61/141 pilot to oversee the work - this is how firms like this are competing with freelancers in the first place because it obviously costs much more to operate an engineering firm than out of a home office and the back of a work truck (no offense intended to any freelancers reading this just saying they are different business models with different marketing advantages and disadvantages). I would actually think the part 107 is a bit too new to really determine industry best practice, as only a handful of years ago a minimum of a sport pilot license (part 61) would have been required.

Does it make a difference (from the businesses perspective) if it were a tuition reimbursement vs. something the employer paid directly for?

Great point on a personal education deduction. I can't say I thought of it from that perspective but as a personal education expense, generally speaking, wouldn't it just need to pass the test that similar test to topic 513 that it would maintain or improve job skills, or your employer requires it to maintain position or salary? I thought the only follow up on that is that it cannot be the base education to qualify you for the job, this is not the case as the person already has their part 107 cert.  Also, it cannot qualify you for a new trade or business; this also passes because a PPL is not a commercial license and in and of itself cannot qualify you for work or income - you would have to go to the next level and get a CPL which I would then say would be completely unnecessary and would flag that second piece that now that person would qualify for a new trade or business because of this education.

Hope its clear I am not trying to argue my point here, I am in fact looking for advice and opinions, I am just trying to make sure I've turned over these areas that seem unclear to me why it would be disallowed.