Before going on to find that an individual who had been making serious and continuing efforts to establish a business of providing for personal software services (albeit unsuccessful to date) was entitled to deduct the costs of a four-week course she took with an enterprise software company in order to upgrade her skills, Woods J. stated (at p.2281):
"The general principle is that training costs will be deductible as a current expense if they are incurred to maintain, update or upgrade an already existing skill or qualification."