The paint removal must be done by a master craftsman in order to maximize the chance that all traces will be removed and minimize the chance that the statue's surface will be damaged in the process. MC worked diligently in 1989 and succeeded in completely removing all visible traces of the paint. T anticipated that the bull would rise in value in future years, and planned to keep it until he can make a larger profit from it. Analyze the dollar amount of insurance premium which cash method taxpayer T may deduct in 1990. T decided to learn more about making money by investing in sculpture.
T pays tuition to take a course in sculpture investing at the local college.
Do not bother looking at any of the 1.162-5 regulations. Assume that the only reason T cannot deduct the tuition cost under Reg. Assume that T comes squarely within this Reg. prohibition, and assume that the only possibility T has of winning a Sec. Explain the manner in which T would need to proceed to succeed in his court challenge of an interpretative regulation. Include Bingler v. Johnson in your answer but do not confine your answer to that case.