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However, we believe this expense is properly characterized as a
portion of petitioner's business expenses, and we shall address
this issue now. Respondent's counsel conceded that petitioner is
entitled to a deduction for such mileage.5 Accordingly,
petitioner is entitled to an additional deduction for mileage
based on 2,662 miles for her return trip to Rochester.
We now consider petitioner's contention that she is entitled
to a deduction for the full amount of the meals expense and is
not subject to the 20-percent limitation as provided in section
274(n). Section 274(n) limits the deduction for meals and
entertainment expenses to 80 percent of such expenses. Section
274(n)(2) provides for certain exceptions to this limitation.
However, petitioner has not shown that any of these exceptions
covers the expenses of meals incurred in connection with her
attendance at a conference, convention, or other similar
5 We note that petitioner also drove from Portland to Los
Angeles where she spent the summer working as a consultant.
However, the 1991 return included a Schedule C for her consulting
business, that reflects a deduction for automobile expenses of
$921.91. Inasmuch as we do not know the details of this allowed
deduction, and petitioner has not made a separate claim for the
trip to Los Angeles, we shall not consider this matter any
further.
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