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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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