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Can a church reimburse a pastor's travel expenses under an accountable reimbursement policy for sabbaticals?

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Nonprofit and Church Legal Trends - Free Edition - November December 2008 (free edition)

PROBABLY NOT. Prior to 1986, the tax code allowed employers and employees to treat "travel as a form of education" as a business expense. However, in 1986 Congress effectively overwrote Section 1.162-5(d) by enacting section 274(m)(2) of the tax code which states, simply, that "no deduction shall be allowed ... for expenses for travel as a form of education."