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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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