Cross References
- Czarnecki, U.S. Court of Federal Claims, October 13, 2017

The taxpayer earned a Bachelor’s of Science degree in engineering in 1994. He then earned a Master’s degree in applied mathematics in 1995. After obtaining his Master’s degree, he began his engineering career working as a plant engineer. In 1996 he worked as a research engineer where he worked on the design and programming of machines to achieve certain gear tooth geometries.

In 1998, he enrolled in a Ph.D. program in structural engineering where he took courses, sat for his doctoral examinations, and presented his dissertation research project.

During the period 2001 to 2006 he worked as a research engineer in Berlin, Germany. He returned to the U.S. in 2007 and began work as a general engineer for the U.S. Navy where he performed structural engineering work for submarine design.

In 2008, the taxpayer became a licensed professional engineer in the State of New York. In 2009, he began work as an engineer at the Navy Surface Warfare Center located in Crane, Indiana. In this position, he focused on how batteries in submarines withstood shocks and vibrational disturbances when the batteries are mounted in a vehicle.

In 2010, the Navy certified the taxpayer as a Systems Engineer Level 3, which involves oversight of the design and manufacture of complex equipment and military hardware. During this period of time, the taxpayer also conducted research and writing in connection with his doctoral thesis for a Ph.D. program in structural engineering at the Massachusetts Institute of Technology. At the time, he was not licensed as a structural engineer.

In 2011, the taxpayer left his employment with the Navy and began working for the Institute for Defense Analyses as a research engineer. In 2014, he began working in his current position as an engineer. In 2014, he ceased work on his doctoral thesis without having obtained a degree.

The taxpayer filed his 2010 tax return claiming an educational expense deduction under IRC section 162 related to required professional development. The IRS disallowed the deduction.

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