- -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.
OPINION
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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