Ann Jorgensen - Page 22

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               In petitioner's case, the U.C. Extension courses involved              
          significant travel and tours.  Although a number of the sites               
          petitioner visited while she participated in the courses were               
          places many tourists would visit while sightseeing in the                   
          respective countries, each site visit served an educational                 
          purpose as part of an organized course of study.                            
               While traveling in Greece and in Southeast Asia, petitioner            
          spent the majority of her time involved in course activity.  The            
          record indicates she was primarily engaged in course activity on            
          all but one of the 18 days that the Legendary Greece course was             
          in session.  During these 17 days, a course itinerary indicates             
          petitioner spent a minimum of 5 hours a day engaged in course               
          activity.  Although a detailed itinerary with the time allocated            
          to specific activities is not available for the Southeast Asia              
          course, petitioner testified that during the Southeast Asia                 
          course most of her time during the day was spent either en route            
          to sites, observing sites, or hearing lectures at the sites.  She           
          further testified that she had minimal free time during the                 
          course which might consist of up to 3 hours on some days.                   
               Given the nature of the educational programs petitioner                
          pursued, it is impossible to separate definitively the personal             
          aspects of petitioner's travel during the time she participated             
          in the U.C. Extension courses from the business aspects.  The               
          fact that she undoubtedly derived personal benefit from her                 

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