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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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