Sherman J. Miller and Alice K. Miller - Page 10

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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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