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through Memphis, Tennessee, and visited Graceland, the former
home of Elvis Presley, the deceased entertainer. While in
Orlando, petitioner wife attended a seminar in connection with
her job at Hercules, and petitioner husband and the children
visited Walt Disney World and Universal Studios. The family also
visited the Kennedy Space Center at Cape Canaveral, Florida, and
several other tourist attractions during their trip. Upon
departing Orlando, the family drove north to Harrisburg,
Pennsylvania, where petitioner husband conducted business with
regard to his real estate sales activity. Once petitioner
husband completed his business, the family drove back to Salt
Lake City. The entire trip encompassed approximately 2-1/2
weeks, and the cost for the automobile rental was $904.59.
On their 1993 Federal income tax return, which they filed on
June 12, 1995, petitioners deducted on Schedule C, Profit or Loss
From Business, among other expenses, $905 for the cost of renting
the automobile used to make the aforementioned Orlando trip. In
the notice of deficiency, respondent made several adjustments,
including the disallowance of the $905 automobile rental expense
deduction. Respondent further determined that petitioners were
liable for the addition to tax, under section 6651(a)(1), for
failure to timely file a Federal income tax return. Prior to
trial, the parties settled all adjustments in the notice of
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