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consultant. While in Guatemala, petitioner and Mr. Maynard
enrolled in the Professional Spanish Language School, which met for
6 hours a day, 5 days a week. Petitioner enrolled for 2 weeks, and
Mr. Maynard enrolled for 4 weeks. Petitioner returned from
Guatemala on November 7, 1989, and Mr. Maynard returned on November
18, 1989.
When a taxpayer's travel takes her outside the United States,
section 274(c) requires an allocation of all expenses in addition
to the other substantiation requirements. No deduction is allowed
for those expenses that are not allocable to the taxpayer's trade
or business. Sec. 274(c)(1). Such allocation is not required,
however, if the travel does not exceed 1 week, or the amount of
time allocated to nonbusiness activities is less than 25 percent of
the total travel time. Sec. 274(c)(2).
Furthermore, when a taxpayer's spouse accompanies her on a
business trip, expenses attributable to his travel are not
deductible unless the taxpayer adequately shows that the spouse's
presence on the trip has a bona fide business purpose other than
the performance of some incidental service. Sec. 1.162-2(c),
Income Tax Regs. The spouse must provide substantial services that
are directly and primarily related to the carrying on of the
taxpayer's business. Weatherford v. United States, 418 F.2d 895,
897 (9th Cir. 1969). The court in Weatherford disallowed a
deduction for the traveling expenses of a wife who did not work on
her husband's wheat farm and who had no specific role in connection
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