Actually, I really don't believe so. The original Reg §1.162-5 was written in 1958 and was amended in 1967. No change since that time.
The Courts (ex Sandt CA3) agreed with the IRS on the "primary purpose" of education in the 1958 regulations. The 1967 amendment sought to offer more objective criteria, removed that concept of subjective intent and also stated "all teaching and related duties shall be considered to involve the same general type of work". Those are the words contained in the regulations contained in TD 6918 published on 5/1/1967.
The Courts (ex Sandt CA3) agreed with the IRS on the "primary purpose" of education in the 1958 regulations. The 1967 amendment sought to offer more objective criteria, removed that concept of subjective intent and also stated "all teaching and related duties shall be considered to involve the same general type of work". Those are the words contained in the regulations contained in TD 6918 published on 5/1/1967.
Comment