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not require that petitioner travel to Europe or anywhere else as
a condition of the sabbatical. It was only as an afterthought,
after petitioner arrived in Spain, that he changed his mind from
completion of the manuscript on an unrelated subject to a study
of the Persian Gulf war from the European point of view. Under
either situation, whether petitioner desired to complete a
manuscript, or to study the European view of the Persian Gulf
war, the travel involved would appear to lie within the examples
of travel described in the legislative history of section
274(m)(2) quoted above of the teacher of French, who travels to
France to maintain general familiarity with the French language
and culture, or the social studies teacher who travels to another
State to learn about or photograph its people, customs,
geography, etc. Here, petitioner's express purpose, after
arriving in Spain, was to learn the European perspective of the
Persian Gulf war. Petitioner's situation falls squarely within
the type of travel Congress intended in enacting section
274(m)(2) in disallowing expenses relating to travel as a form of
education. On this record, petitioner has not established that
the deductions claimed were a necessary adjunct to engagement in
an activity giving rise to a business deduction relating to
education that Congress intended to remain as an allowable
deduction. Respondent, therefore, is sustained on this issue.
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