Harry T. Cavalaris - Page 15

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              Petitioner typically stayed at "deluxe" hotels during his              
          travels.  For instance, on a trip to Baltimore, Maryland                    
          (paragraph 9 of the stipulation of facts), petitioner stayed at             
          the Peabody Court at a rate of $180 per night.  Similarly, on an            
          11-day AHEPA trip to Fort Lauderdale and Miami Beach, Florida               
          (paragraph 10 of the stipulation of facts), petitioner stayed at            
          the Sheraton Bonaventure Resort and Spa and the Doral Ocean Beach           
          Resort, respectively, incurring lodging charges of $1,602.69.               
          Respondent does not dispute the need for lodging on these or                
          similar trips, but rather the reasonableness of the expenditures.           
          While few would characterize petitioner's choices of                        
          accommodations as frugal, they were generally convenient.                   
          Petitioner often stayed at the hotel hosting the meeting he was             
          attending.  When petitioner could not obtain a room at the hotel            
          hosting the meeting he would stay at a similarly priced hotel in            
          the vicinity.  This practice saved petitioner additional travel             
          costs.  In addition, petitioner held relatively prestigious                 
          positions in large charitable organizations, such that staying in           
          quality lodgings may have been acceptable practice.  Bearing in             
          mind that reasonableness is a relative term, we conclude that               
          petitioner's expenditures for lodging were reasonable.                      
               Respondent also contends that expenses incurred for the                
          rental of a suite during a trip to Washington, D.C. (paragraph 14           
          of the stipulation of facts), in excess of the ordinary room                





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