Robert D. Grossman, Jr. - Page 147

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          function, petitioner contends that the Sley Corporations business           
          purpose in most such instances is that the travel was undertaken            
          so that Betsy could confer with Beatrice or petitioner, or                  
          sometimes with Ben, about Sley Corporations business.                       
               Petitioner states his view of the situation as follows in              
          his answering brief:                                                        
                    Every trip Petitioner and Betsy took was partly related           
                    to business.  On the trips, petitioner and Betsy would            
                    talk about business and about the Sley Corporations               
                    continuously.                                                     
                    In the context of closely held, personal holding                  
                    companies differentiating between shareholder purpose             
                    and corporate purpose makes no sense because the                  
                    shareholders and their corporation generally have                 
                    identical interests.                                              
               Of course, a trip that is primarily for the taxpayer’s                 
          individual pleasure is not converted into a business trip merely            
          because some short portions of the trip involve business                    
          activities, even when it is clear that the asserted business                
          activities actually occurred and that those business activities             
          actually affected the cost of the trip.  This has been the rule             
          under section 162 and its predecessors, even without regard to              
          the restrictions of section 274, enacted in 1962.  E.g., George             
          R. Holswade, M.D., P.C. v. Commissioner, 82 T.C. 686 (1984);                
          Hoover v. Commissioner, 35 T.C. 566 (1961).                                 
               In the instant cases, we doubt that there were significant             
          business discussions on these trips.  Petitioner’s general                  
          testimony about business discussions was sometimes disputed by              




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