Hi, thanks for the response. Consider this response rhetorical as my intentions are again not to argue just understand why this particular deduction is so likely to be rejected in an audit and have a discussion about it. The hypotheticals aren't really hypotheticals but a pretty specific set of facts, I believe what you are interpreting as hypothetical is that I am asking if not a simple write-off of expenses then hypothetically which way is less offensive to the IRS and I believe you answered that by saying that if it were included as a fringe benefit essentially and then the employee takes the education write off as a requirement of their position to maintain the same position and salary.
What my last post was pondering was if not this, than what justifies ordinary and necessary for continuing education expenses? Its not hypothetical that its a furtherance of knowledge in the field and its a fact that the new license does not qualify them for any new career as it is non commercial; therefore, it is, and only can be, a furtherance in their field from an economic standpoint other than that there is a recreational opportunity that exists when completed. I suspect that is the reason it is looked at so critically, the likelihood of abuse, much the same as writing off a new roof under photovoltaic panels (you are only supposed to claim what's needed to do the PV but some people then try to write off the entire roof); people too often don't deduct this specific license honestly; therefore, they are more critical of it than if a therapist took a class on Internal Family Systems or a business executive is expected to get an MBA and writes it off.
One true hypothetical, I wonder if it makes a difference if someone only claims the classes but not the license itself (i.e. does not claim the checkrides, exam fees, etc.) as the license itself is unnecessary, just the knowledge. But again as a devil's advocate, the FAA acknowledged that the Part 107 is a minimum necessary knowledge and now allows a Part 61 pilot to simply take a supplemental knowledge course and must remain current and does not require Part 107 at all which complicates the former scenario. However, again truly hypothetical in this case, since one could choose to operate a drone using Part 61 instead of Part 107, does the IRS require you take the cheapest path to the same result if a particular pilot to be does not already have Part 107?
