The Department of Taxation and Finance has ruled that tuition expenses for only the first two years of a university’s six-year combined undergraduate and doctorate pharmacy program meet the definition of “qualified college tuition expenses” deductible under Tax Law § 606(t)(2)(C), which excludes tuition for “a post baccalaureate or other graduate degree.” Advisory Opinion, TSB-A-12(6)I (N.Y.S. Dep’t of Taxation & Fin., Oct. 15, 2012). The Department reasoned that tuition payments for the first two years of pre-pharmacy undergraduate study before the student was formally admitted into the pharmacy doctorate program were qualified college tuition expenses because (i) students paid the regular university tuition and not the special professional tuition rate applicable once they were formally admitted to the doctorate program, and (ii) students could apply the credits from their two years of undergraduate pre-pharmacy study toward a bachelor’s degree if they were not admitted to, or chose not to go into, the doctorate program. The Department also noted that although the Doctor of Pharmacy was a professional degree and not a graduate degree, it was analogous to a “post baccalaureate” degree under the statute because while students did not need a bachelor’s degree to be enrolled, they could apply to the program after earning one.