Ann Jorgensen - Page 4

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               In 1996, petitioner attended a U.C. Extension course                   
          entitled "Southeast Asia:  Sacred Places" (Southeast Asia) to               
          study how the religious traditions of Buddhism and Hinduism have            
          shaped and continue to shape the culture of Southeast Asia.  The            
          course took place in Thailand, Cambodia, and Indonesia from                 
          December 27, 1996, to January 11, 1997.  Petitioner paid the                
          following amounts in connection with the Southeast Asia course              
          and deducted the total amount on her 1996 Federal income tax                
          return as an employee business expense:                                     
               U.C. Extension:                                                        
               Tuition, meals, lodging                 $4,500                         
               Airfare                                 2,235                          
               Visas, transfers, taxes, misc.          1,070                          
               Total                                   7,805                          
               Both of these courses were taught by university professors             
          and qualified for upper division, undergraduate U.C. Extension              
          credit.  In both courses, credit requirements included the                  
          completion of a research paper.  Petitioner did not seek or                 
          obtain credit for the courses.                                              
               Both courses had focused academic purposes and consisted of            
          a series of formal lectures and visits to historical and cultural           
          sites.  The Legendary Greece course had a required reading list             
          for all attendees, and the Southeast Asia course required reading           
          only for attendees seeking credit.  Petitioner completed all                
          credit requirements for the courses with the exception of the               
          research papers.  Petitioner's employer did not require her to              

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