- 17 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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