- 18 - Her research was used by petitioner at the Omaha, Nebraska, conference. On their 1991 Federal income tax return, petitioners claimed unreimbursed employee business expenses of $1,525.32 for the travel expenses incurred by Mrs. Rezazadeh for her research trip to Bogota. More specifically, the expenses claimed included the standard mileage rate for automobile travel from petitioners' home in Platteville to the airport in Chicago, Illinois, and back to Platteville, the round-trip airfare from Chicago to Bogota, miscellaneous meals and lodgings in Chicago, parking at the Chicago airport, meals in Bogota, and the Bogota Airport departure tax. Expenses for lodging in Bogota were not claimed because Mrs. Rezazadeh stayed with her relatives. In the notice of deficiency, respondent disallowed the claimed employee business expenses, determining that the primary purpose of the trip was for pleasure, not business. At trial, respondent acknowledged that Mrs. Rezazadeh did spend some time doing research while she was in Bogota. Section 162(a) allows a deduction for all ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business. Such deductions include traveling expenses incurred while away from home in the pursuit of a trade or business, including amounts expended for meals and lodging. Sec. 162(a)(2). If travel expenses are incurred forPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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