- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011