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be claimed only on the ground that the travel itself is
"educational", but permits deductions for travel that
is a necessary adjunct to engaging in an activity that
gives rise to a business deduction relating to
education. [H.Rept. 99-426, at 122 (1985), 1986-3 C.B.
(Vol. 2) 1, 122.]
Petitioner argues that her travel was not travel as a form
of education within the meaning of section 274(m)(2) because she
traveled to participate in academic courses, and thus, the travel
was "a necessary adjunct to engaging in an activity that gives
rise to a business deduction relating to education." Respondent,
on the other hand, contends that petitioner's travel does not
differ materially from any organized group tour with a
knowledgeable group leader. We agree with petitioner that the
U.C. Extension courses fall outside the scope of section
274(m)(2).
Both of the courses had focused educational purposes beyond
mere travel as evidenced by the fact that university credit was
available for the courses. Unlike the example of a French
teacher improving her familiarity with the French language and
culture simply through traveling in France, the U.C. Extension
courses were conducted on an organized basis with regular
lectures from university professors and planned tours of
historically and culturally significant sites directly related to
the course of study. Petitioner's participation in the courses
involved following structured syllabi and completing significant
reading assignments. Both U.C. Extension courses and instructors
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