otels. She would claim that money earned while in school full-time should not be taxed because she was simultaneously paying for her education. The Commissioner ruled based on the Australian tax code that the deduction was not legitimate as was found in earlier cases such as Lunney v. Commissioner of Taxation (497), as well as Commissioner of Taxation v. Cooper (197), and Commissioner of Taxation v. Hatchett (82).
A number of cases such as Commissioner of Taxation v. Studdert (83) established the principle that educational expenditures should be relevant to one's employment activities as well as incidental to those activities. What must be established is a continuing employment relationship at the time when the expenditure is incurred which was affirmed in Commissioner of Taxation v. Maddalena (426) and later, in Federal Commissioner of Taxation v. Kropp (375).
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