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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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