- 22 - which is near a small community where one of her clients resided. Petitioner points to a billing statement in that client's file, in which one line reads "Travel Time and Mileage" and is dated June 30, 1989, as corroborative evidence of the business purpose of this expenditure. We do not think that this sufficiently corroborates the time, place, and business purpose for the expenditure as required by section 274(d). Petitioner claimed a deduction in the amount of $418 for a room at the Adobe Resort Motel in Yachats, Oregon. Petitioner introduced a credit card statement listing the expenditure. Petitioner testified that the purpose of the trip was to investigate various plans for clients. While she was there, petitioner allegedly contacted a Captain Schones and spoke to him about the prospect of her clients' working in the fishing industry. Petitioner further testified that a "majority" of the trip was for business purposes. While we think that petitioner has adequately substantiated the amount of the expense and the time and place such expense was incurred, petitioner has introduced no evidence to corroborate her testimony as to the business purpose of the trip. Accordingly, we uphold respondent's determination. Petitioner claimed a deduction in the amount of $274, which was paid to Shingle Travel Agency for airline travel for Renata to Bakersfield, California. The check payable to Shingle Travel Agency bears the notation "Rosa Garcia Conference". Petitioner testified that the purpose of Renata's trip was to monitor aPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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