- 25 -
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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