Harry T. Cavalaris - Page 24

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          allowed by respondent in the stipulation of facts.7  On all other           
          trips, for which we conclude petitioner is entitled to a                    
          deduction for travel expenses, petitioner is entitled to deduct             
          the amount claimed for meals as set forth in the stipulation of             
          facts.                                                                      
               Respondent contends that the expenses of certain entire                
          trips are not deductible because they involved elements of                  
          personal pleasure, recreation, or vacation.  Respondent                     
          particularly takes issue with petitioner's trips to Virginia                
          Beach, Virginia; Nassau, Bahamas; Fort Lauderdale, Florida;                 
          Athens, Greece; and Istanbul, Turkey.  Respondent notes:  (1) A             
          letter describing the activities planned for the Virginia Beach             
          AHEPA conference compared the trip to a "mini-vacation"; (2)                
          petitioner received a facial and massage while in Nassau; and (3)           
          petitioner enjoyed the use of a spa while in Fort Lauderdale.               
          The trips to Athens and Istanbul require more explanation.                  
               Petitioner traveled to Athens on August 28, 1991 (first                
          trip); Athens and Istanbul on October 4, 1991 (second trip); and            


          7   In making their Rule 155 computations, the parties                      
          should note:  (1) We disallowed $67.69 of meal expenses relating            
          to the Washington, D.C., trip on July 7-12, 1990 (par. 14 of the            
          stipulation of facts) for duplication; (2) "meals" includes the             
          board dinner listed in par. 18 of the stipulation of facts; and             
          (3) respondent conceded a deduction of $1,116 for two "banquets"            
          relating to the Birmingham, AL, trip on May 29-31, 1991 (par. 33            
          of the stipulation of facts).  Accordingly, as applied to the               
          Birmingham trip, the disallowance relates only to the item listed           
          as "meals".                                                                 




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