- -13
expenses connected with the condominium. Since he was an
insurance agent, he decided that when he was in the Hayward area
he would on occasion speak to a golfing partner or dinner
companion about insurance and thereby justify deducting the costs
connected with the condominium and his trips to Hayward.
We, therefore, sustain respondent's disallowance of
petitioners claimed travel expenses to the Hayward area from
Roseville. Because we have concluded that the travel expenses
are not deductible since they were not incurred primarily for
business purposes, we need not address the issue of whether the
expenses were reasonable.1
Next at issue is whether petitioner is entitled to deduct
country club dues during the years at issue. Section 274
generally disallows deductions for expenses for entertainment
facilities, unless the taxpayer establishes that the facility was
used primarily for the furtherance of the taxpayer's trade or
business and that the item was directly related to the active
conduct of such trade or business. Sec. 274(a)(1)(B); sec.
274(a)(2)(C). In order to show that the facility was used
primarily for the furtherance of a taxpayer's trade or business,
the taxpayer must show that the actual use of the facility during
1 For these same reasons, we also find that petitioners are
not entitled to a deduction under sec. 212. In order for
petitioners to be entitled to a deduction under sec. 212, the
predominant purpose and use of the property must not be for
recreation, a hobby, or some other nonprofit motive. Sec. 1.212-
1(c), Income Tax Regs.
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