Facts
The appellant [M.] graduated from high school with a Matura in 1988 and then began studying economics, which he abandoned in 1990. In the following years, he initially worked as a self-employed Apple Macintosh supporter and then joined [X. AG] in 1995, where he was active in the areas of acquisition, consulting and sales. In 1998, he moved to [Y. AG] , where he has been working as a "Business Development Manager" since July 2001. From 1997 to 1999, he completed a part-time Bachelor of Business Administration (BBA) program, the costs of which were recognized by the tax office as continuing education costs. For the 1999 tax period, [M.] claimed continuing education and retraining costs of CHF 27,542.-- as he had undergone part-time training to become a "Master of Business Administration" (MBA). In addition to the school fees of CHF 16,850.-- , this amount also included CHF 5,742.-- for a computer and CHF 4,950.-- for a study room in his private apartment. However, the Cantonal Tax Office of Zurich only recognized a lump-sum deduction of CHF 400.--. [M.] unsuccessfully filed an objection and appeal against this assessment.Considerations
The Federal Supreme Court upheld the decisions of the lower instances, not recognizing the costs for the MBA program as tax-deductible continuing education costs. The training for the MBA should rather be qualified as initial training or career advancement costs, which are not deductible according to Art. 34 lit. b DFTA. Although [M.] had initially started an economics degree after high school, he had abandoned it. The subsequent training for the BBA and MBA is therefore to be seen as catching up on the…