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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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