Betty J. Shackelford - Page 22

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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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