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6662(a) in the amount of $599 with respect to petitioner's 1991
tax year.
The issues for decision are: (1) Whether certain
educational expenses incurred by petitioner constitute
nondeductible travel expenses for education under section
274(m)(2), and (2) whether petitioner is liable for the accuracy-
related penalty under section 6662(a).
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner's
legal residence was in the State of California.
During the year at issue, petitioner was employed as a
professor of international relations by San Francisco State
University at San Francisco, California (the University). The
department of international relations at the University is part
of the School of Behavioral and Social Sciences. Petitioner
began his employment with the University in the fall of 1964,
having a bachelor of arts degree in psychology and master and
doctorate degrees in political science. After the year at issue,
petitioner retired in October 1992 as professor emeritus.
As petitioner described it at trial, the academic field of
international relations mainly involves international politics
and encompasses social, economic, political, and cultural
relations among nations. As a professor of international
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