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courses given at Worcester College at Oxford, England.
Petitioner further testified that the courses’ objective was to
aid teachers in their teaching of high school English courses,
including advanced placement courses. Petitioner did admit that
these courses were not required as a condition for his employment
with the Chicago Department of Education and that he and his wife
had made this trip every summer for several years, during which
time he attended these courses at Worcester College at Oxford.
In this case, petitioner has attempted to substantiate his
expenditures through his own self-serving testimony. At trial,
petitioner testified: (1) In taxable year 1999 and preceding
years, he and his wife would fly to England for the last 2 weeks
in July; (2) while in England, petitioner attended courses at
Worcester College at Oxford; (3) these courses furthered his
ability of teaching English and advanced placement courses.
Petitioner further testified that while in England, he and his
wife stayed at Bruern Cottages and that he rented a Mazda RX-7 in
order to get back and forth from Bruern Cottages to Worcester
College.
Petitioner claims that the $33,785 miscellaneous deductions
for job expenses incurred during taxable year 1999 were for the
price of his and his wife’s air fare to England, meals while in
England, books purchased for the courses at Worcester College,
the rental cost of the Mazda RX-7, and the price of the Bruern
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