Ann Jorgensen - Page 15

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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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