Your client, Professor Smith, obtained tenure and a promotion to full professor status many years ago. Yet, he continues to publish research papers in scholarly journals to satisfy his own curiosity and maintain his professional prestige and status within the academic community. Publications are also considered by the college when deciding whether to give pay raises to tenured faculty. This year, Dr. Smith spent $8,750 of his own funds to travel to southern Utah to collect some critical pieces of data for his work.

Before leaving for his trip, Professor Smith, who is also a landlord for several students that rent apartments in a building that Professor Smith owns on campus, obtained internet services for each of the rental units from a new internet and cable provider. The new internet provider required a $225 refundable deposit from new customers in lieu of a credit check. Professor Smith paid the amount for each of his 6 tenants.

Please prepare a memorandum to me using the following format:
Issue,
Authority,
Analysis,
Conclusion.

The memo (which should be at least 2 but no more than 4 pages in length) should address whether the $8,750 travel expenses, and/or the $225 per tenant expense referenced above can be deducted by Professor Smith. For full credit the memo should cite to at least one source from each of the three sources of primary authority (i.e. at least one case, one code section and item of administrative guidance)