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potential client was "anyone that is living and breathing and of
appropriate age". If petitioner asked a golfing partner whether
he needed insurance, he considered the game to be a business
meeting and the expenses connected with that meeting deductible.
Petitioner's wife accompanied petitioner on 50 to 60 percent
of his trips to Hayward. Petitioner testified that his wife
accompanied him on these trips as a chauffeur, but there is
nothing in the record to indicate that petitioner needed a
chauffeur as an ordinary and necessary business expense.
Based on the record, we conclude that petitioners' trips to
Hayward were primarily for personal activities, and, therefore,
they are not entitled to deduct the travel expenses to Hayward or
the expenses related to the condominium under section 162.
Petitioner testified that he only visited Hayward during the
summer months. Petitioner testified that he played golf "usually
with a prospect or a client", implying that he also played golf
without clients. Petitioner's wife testified that she used the
condominium for personal use, including knitting and
embroidering, and that she shopped in the Hayward area while on
her trips there. The fact that petitioner's wife accompanied him
on a substantial number of his trips to Hayward, without a
showing that she assisted petitioner in any business activities,
further indicates that the trips were primarily personal.
Petitioners maintained a boat in Hayward. They claimed that the
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