Sherman J. Miller and Alice K. Miller - Page 12

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            deductions were for such activities as playing golf or having                             
            dinner with persons he considered potential clients, since                                
            occasionally he would ask them whether they needed insurance.                             
            Petitioner claims such activities were business meetings.  Under                          
            section 162, however, a more direct, primary relationship to the                          
            production of business income must be shown to establish that                             
            such a meeting is a business meeting.  Henry v. Commissioner, 36                          
            T.C. 879, 884 (1961).  Since petitioner has failed to prove that                          
            the trips to Hayward were more business than personal, the                                
            claimed costs associated with these trips are not deductible.                             
                  We are also unpersuaded by petitioner's argument that other                         
            lodging in the Hayward area during the summer months was not                              
            reasonably available.  Petitioner testified that a depressed                              
            rental market was the reason he did not continue to use the                               
            condominium as rental property.  Another witness, Mrs. Janet                              
            Loftus, testified as to the availability of hotels and                                    
            condominiums in the area.  The availability of lodging                                    
            accommodations in Hayward was also testified to by Mrs. Carolyn                           
            Butterbaugh.  Petitioner testified that condominiums rented for                           
            "about $100 a day".  We find that the evidence indicates that                             
            other lodging would have been available to petitioner at a cost                           
            far less than maintaining the condominium.  In our view,                                  
            petitioner merely decided that he was dissatisfied with his                               
            rental income from the condominium and would find another use for                         
            it under which, in his view, he would be entitled to deduct the                           

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