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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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