In the United States Court of Federal Claims
No. 15-1381'1`
Filed october 13, 2017 F| l_ED
NOT FOR PUBLICATION l 7
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)
U.S. COURT OF
JERRY JOHN CZARNECKI, JR., § FEDERAL C|_AIMS
Plaintiff, )
) Pro se; Summary Judgment, RCFC 56;
v. ) Ordinary and Necessary Business
) Expense, Internal Revenue Code § 162;
'I`HE UNITED STATES, ) Treasury Regulations § 1.162-5.
)
Defendant. )
)
Jerry J()hn Czar"necki, Woodbridge, VA, plaintiff pro ,s'e.
Jason S. Selmom, Attorney of Record, Blaine G. Saito, Trial Attorney, Mary M. Al)are,
Assistant Chief, Davz'd [. Pincus, Chief, Davz'cl A. Hul)bert, Acting Assistant Attorney General,
Court of F ederal Claims Section, Tax Division, United States Department of lustice,
Washington, DC, for defendant.
MEMORANDUM OPINION AND ORDER
GRIGGSBY, Judge
I. INTRODUCTION
In this tax refund matter, plaintiff pro se, Jerry John Czarnecki, seeks to deduct certain
educational expenses incurred in connection with researching and writing his doctoral thesis as
an ordinary and necessaly business expense, pursuant to Section 162 of the Internal Revenue
Code and Treasury Regulations § l.162-5. See generally Compl. The parties have filed cross-
motions for summary judgment on the issue of Whether plaintiff is entitled to deduct these
expenses, pursuant to Rule 56 of the Rules of the United States Court of F ederal Claims
(“RCFC”). See generally Def. Mot.; Pl. Mot. For the reasons discussed below, the Court
GRANTS the government’s motion for summary judgment and DENIES plaintiffs cross-
motion for summary judgment
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II. FACTUAL AND PROCEDURAL BACKGROUNDl
A. Factual Background
Plaintiff is a professional engineer Compl. at i'l; Def. Mot. at l. ln 2010, plaintiff
engaged in research and Writing in connection With his doctoral thesis for a Ph.D. program in
structural engineering at the Massachusetts Institute of Technoiogy (“MIT”). Def. Mot. at l. ln
this tax refund action, plaintiff seeks to deduct these educational expense as an ordinary and
necessary business expenses, pursuant to Section 162 of the Internal Revenue Code (“I.R.C.”)
and Treasury Regulations § l.162~5. See generally Compl.
1. Plaintiff’s Educational Background And Work History
The material facts in this tax refund case are undisputed Plaintiff has studied and
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