Betty J. Shackelford - Page 25

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          with the farm other than discussing business matters with her               
          husband.  Id.  Similarly, in the present case, petitioner did not           
          show that Mr. Maynard had a specific role in connection with her            
          business.                                                                   
               With respect to the trip to Guatemala, petitioner deducted             
          $96.09, which she paid to the Hotel Del Lago in Guatemala.                  
          Petitioner introduced a charge statement listing the charges to             
          this hotel in order to substantiate the expenditures.  Petitioner           
          also deducted $15.00, which she paid to the Hotel Sol-Mor in                
          Guatemala.  Petitioner introduced a receipt from the hotel that was         
          made out to Mr. Maynard and reflected the price of the room in              
          quetzals.12  Moreover, petitioner deducted $1,124 for the airline           
          tickets to Guatemala for Mr. Maynard and herself, for which she             
          introduced boarding passes and Mr. Maynard's airline ticket.                
               Not only has petitioner failed to allocate her foreign travel          
          expenses between business and nonbusiness as required by section            
          274(c), but petitioner has also failed to show that Mr. Maynard's           
          presence on the trip to Guatemala had a bona fide business purpose,         
          see sec. 1.162-2(c), Income Tax Regs.  Accordingly, we sustain              
          respondent's disallowance of a deduction for petitioner's foreign           
          traveling expenses.                                                         


          12The quetzal is the basic unit of currency in Guatemala.                   
          The receipt reflected an amount due of 46.80 quetzals.                      
          Petitioner deducted an equivalent amount in U.S. dollars.                   
          Respondent has not challenged petitioner's exchange rate                    
          computation; therefore, we will accept it for purposes of                   
          deciding this issue.                                                        



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