- 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.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011