- 90 - 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 byPage: Previous 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 Next
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