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petitioner is entitled to $103 of the disallowed deductions for
1995 and $320 of the disallowed deductions for 1996. The
remaining disallowed deductions are for the expenditures
associated with petitioner's participation in the Legendary
Greece and Southeast Asia courses. Respondent maintains that
these expenses were incurred for travel as a form of education
and that such expenses are nondeductible under section 274(m)(2).
In the alternative, respondent argues that even if the expenses
are for education other than that which resulted from the travel
itself, the expenses are nevertheless not deductible under
section 162 because they are not ordinary and necessary business
expenses.
Discussion
Section 162(a) permits a deduction for all ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business. Such expenses generally include
expenditures for travel, including amounts expended on meals and
lodging, while away from home in the pursuit of a trade or
business. See sec. 162(a)(2).
In contrast, no deductions are allowed for personal, living,
or family expenses unless otherwise expressly provided by the
Internal Revenue Code. See sec. 262(a). Expenditures made by a
taxpayer in obtaining or furthering education are considered
personal expenses and are not deductible unless they qualify
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