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strengthen the * * * University's visibility." Seton Hall's
faculty guide provided: "The major purpose of a sabbatical leave
is to provide the opportunity for continued professional growth
and new or renewed intellectual achievement through study,
research, scholarly writing, or professionally related travel."
The faculty guide further provided that faculty members on
sabbatical leave must obtain written approval of the provost
before accepting paid employment.
In support of his sabbatical leave in 1993, petitioner
accepted an appointment as a "Senior Fellow" at the National
University of Singapore (NUS). Ms. Kant was on leave without pay
during that period. Petitioners resided in Singapore for
approximately 5 months during the 1993 taxable year. While in
Singapore, petitioner engaged in research and prepared a seminar
paper which was presented to the Department of Economics at NUS.
NUS provided petitioner with an office and library access, as
well as housing and child care benefits. The record does not
contain any detailed documentation concerning the precise nature
of petitioner's relationship with NUS.4 Furthermore, the record
does not indicate whether petitioner received written approval
from Seton Hall before accepting the appointment at NUS.
Petitioner received $27,191 from NUS during the 1993 taxable
year. The Inland Revenue Authority of Singapore treated
4 Petitioners maintain that some of their documentation was
destroyed by rain.
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Last modified: May 25, 2011