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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 a
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