Sherman J. Miller and Alice K. Miller - Page 8

                                                -  -8                                                   
           Petitioner kept some of his receipts relating to the Hayward area                          
           in a drawer.                                                                               
                 Respondent in her notice of deficiency disallowed the                                
           deductions claimed by petitioners for expenses relating to the                             
           condominium and the 1986 van, and the deduction claimed for                                
           country club dues for each of the years 1987 and 1988 on the                               
           basis that petitioners' trips to Hayward were primarily personal                           
           and the primary use of the condominium was personal, and that                              
           petitioner had not established that the country club dues were                             
           deductible.  Respondent determined that the real estate taxes on                           
           the condominium were deductible as an itemized deduction on                                
           Schedule A.                                                                                
                 In 1987 petitioners claimed $4,419 for meals and                                     
           entertainment on Form 2106.  Respondent has conceded $1,050 of                             
           this amount, and petitioner has conceded $1,469. In 1988                                   
           petitioners claimed $3,245 for meals and entertainment.                                    
           Petitioners have conceded $917 of this amount.  Of the amount                              
           originally claimed, $1,900 and $2,328 of dues expenses paid to                             
           the country club remain at issue for the taxable years 1987 and                            
           1988, respectively.                                                                        
                 Section 162(a)(2) allows as a deduction all the ordinary and                         
           necessary expenses paid or incurred during the taxable year in                             
           carrying on any trade or business, including traveling expenses                            
           while away from home in the pursuit of a trade or business.  Sec.                          

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