Reza and Connie M. Rezazadeh - Page 17

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          the facts of this case are distinguishable from the facts of the            
          cases relied on by petitioner.4                                             
               The second issue relates to travel expenses incurred by Mrs.           
          Rezazadeh during 1991.  Petitioner was scheduled to present, in             
          his capacity as a political science professor at the University,            
          a paper on local government in the nation of Colombia in October            
          1991 at the Third World Studies 14th National Conference held at            
          the University of Nebraska at Omaha, Nebraska.  Preparing such a            
          paper required extensive research in Bogota, Colombia.  Due to              
          other commitments, petitioner was unable to travel to Bogota to             
          conduct the necessary research.  Petitioner asked his wife, Mrs.            
          Rezazadeh, who is of Colombian origin, to travel to Bogota to do            
          the research for the paper.  Mrs. Rezazadeh has a doctoral degree           
          in psychology (degree).  Having written an extensive dissertation           
          to complete the degree, Mrs. Rezazadeh was knowledgeable of the             
          research process.  Furthermore, being of Colombian origin and               
          having relatives in Bogota, Mrs. Rezazadeh was very familiar with           
          local offices and institutions in Colombia.  Mrs. Rezazadeh                 
          traveled to Bogota on May 27, 1991, and returned to the United              
          States on July 25, 1991, for a total travel period of 60 days.              

          4                                                                           
               The case of Stratmore v. Commissioner, 292 F. Supp. 59 (D.             
          N.J. 1968), revd. 420 F.2d 461 (3d Cir. 1970), relied on by                 
          petitioner on brief, was the opinion of the U.S. District Court             
          that held that the debt in question was a business bad debt.                
          Interestingly, that holding was reversed by the Court of Appeals            
          for the Third Circuit.  Petitioner did not cite nor discuss the             
          Court of Appeals' reversal.                                                 




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