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reimbursement program for mariner continuing education that
covered tuition, hotel, and meal expenses for mariner continuing
education courses, but not for travel expenses.
On the Sailor Travel Statement attached to petitioners’
return for 2002, petitioners explained that the purpose of
petitioner’s trip to Fort Lauderdale was to attend a continuing
education program, the tuition for which was paid by petitioner’s
union. At trial, petitioner testified that he attended a
firefighting school with colleagues. Although given the
opportunity, respondent did not question petitioner regarding the
business purpose of the Fort Lauderdale trip or the business
benefit that petitioner hoped to derive from his attendance at
the firefighting school. Respondent’s only question on
cross-examination regarding the Fort Lauderdale trip was whether
petitioner kept a mileage log to substantiate the miles traveled
on that trip. Petitioner answered in the negative.
We hold that petitioner has adequately substantiated the
business purpose of his travel expenses related to the Fort
Lauderdale trip for firefighting school. Firefighting is related
to petitioner’s employment as a merchant sailor and engineer.
Payment for the course by petitioner’s professional union
supports petitioners’ characterization of the related travel
expenses as ordinary business expenses. We are not persuaded by
respondent’s argument that, because petitioner did not seek
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