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Ps, husband, and wife, resided in Hacienda Heights, California. They were employed as science teachers by the Los Angeles Unified School District. Approximately 25 percent of Mrs. Takahashi's students were minorities, while almost all of Mr. Takahashi's students were minorities. Most of the minority students taught by Ps were Hispanic. California State Education Code requires that each teacher must complete a minimum of two-semester units in a course of study dealing with multicultural societies to receive promotions and salary increases. Ps attended a seminar held in Hawaii entitled 'The Hawaiian Cultural Transition in a Diverse Society' which satisfied the California requirements. Ps, together with their 2 1/2-year-old son, spent 10 days in Hawaii. The seminar was for 9 out of the 10 days and lasted from 1 to 6 hours each day and consisted of classroom instruction as well as tours of Polynesian cultural attractions and visits to the homes of local natives. When not participating in the seminar, they would take their son sightseeing or spend time relaxing at the beach. Ps claimed the expenses as an education expense under section 162(a). IRS (D) disallowed this deduction. Ps petitioned.

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