Theodore W. Keller - Page 8

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                  In H. Rept. 99-426 (1985), 1986-3 C.B. (Vol. 2) 1, 122, the                             
            Committee on Ways and Means of the House of Representatives                                   
            reported:                                                                                     

                  Travel as a form of education                                                           
                        The committee is concerned about deductions claimed for                           
                  travel as a form of "education."  The committee believes                                
                  that any business purpose served by traveling for general                               
                  educational purposes, in the absence of a specific need such                            
                  as engaging in research which can only be performed at a                                
                  particular facility, is at most indirect and insubstantial.                             
                  By contrast, travel as a form of education may provide                                  
                  substantial personal benefits by permitting some individuals                            
                  in particular professions to deduct the cost of a vacation,                             
                  while most individuals must pay for vacation trips out of                               
                  after-tax dollars, no matter how educationally stimulating                              
                  the travel may be.  Accordingly, the committee bill                                     
                  disallows deductions for travel that can be claimed only on                             
                  the ground that the travel itself is "educational", but                                 
                  permits deductions for travel that is a necessary adjunct to                            
                  engaging in an activity that gives rise to a business                                   
                  deduction relating to education.                                                        

                  Petitioner argues that the work he performed in Spain could                             
            not have been performed in the United States and necessarily                                  
            required foreign travel because the European perspective of the                               
            Persian Gulf war was not made known or publicized by the news                                 
            media in the United States.  That argument, however, is                                       
            misdirected because petitioner did not apply for a sabbatical                                 
            leave in order to make a study of the Persian Gulf war.                                       
            Petitioner's intent and purpose in taking the sabbatical and in                               
            traveling to Spain was to complete a manuscript on an unrelated                               
            subject he had begun several years before.  The University did                                





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