"Like many S-corp owners they don't follow the rules regarding salary even when we tell them to."

The person is a Shareholder; the S Corp doesn't have an Owner. It's pretty hard to show the S Corp has anything to do with this person's (re-)education, when their non-action results in no employment relationship to the entity trying to take this deduction as if it is related to the entity. You cannot even take advantage of the Tuition Reimbursement rules.

In other words, the person has treated themself as an investor, and now they suffer the consequence of the corner they put themself into. Tell them the full picture and see if they want to start to follow the rules.