Although the taxpayer was already employed as a pilot, the study was designed to enable the taxpayer to obtain new employment and did not relate to their current income earning activities.
It still seems to be a matter of interpretation. Is the phrase "current income earning activities" referring specifically to the employer you work for or, generally speaking, the line of work you are in (commercial pilot)?
I would have thought the latter.
Say for instence you hire a simulator to maintain I/F currency @ $100/hour. This is tax deductable.
Now say you hire a 747 simulator to do the same. No difference. Same out come is achieved, just at a much higher expenditure.
Now, say it took $20-30,000 to do the above currency work and you ended up with a 747 endorsement.
How can the ATO differentiate? A simulator is a simulator is'nt it?
