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teaching skills. Petitioner testified that, before taking the
course, she sometimes had difficulty determining when an Asian
student's response to a piece of literature signified a problem
with reading comprehension or was a cultural response to a theme
the student had difficulty understanding. Petitioner testified
that the course has improved her ability to assess students'
responses and help them understand themes in literature.
Petitioner's study in Southeast Asia enhanced her skills beyond
merely helping her to increase rapport with her Asian students.
See Dollins v. Commissioner, T.C. Memo. 1982-394. But see Gino
v. Commissioner, 60 T.C. 304, 310-311 (1973), revd. on other
issue 538 F.2d 833 (9th Cir. 1976). Petitioner has incorporated
much of the knowledge she gained and many of the skills she
acquired in the Southeast Asia course into her English classes.
See Dollins v. Commissioner, supra.
Respondent acknowledges that petitioner's participation in
the U.C. Extension courses has improved her skills by helping her
relate to her students and develop curriculum for both her
classes and the English department, but respondent maintains that
petitioner's skills improved as a result of her travel and not as
a result of the courses. Although petitioner was required to
travel to participate in the courses, it was the content of the
courses that directed petitioner's attention to materials that
enhanced her teaching. Through the course lectures and readings,
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