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both business and other purposes, the travel expenses are
deductible only if the travel is primarily related to the
taxpayer's trade or business. Sec. 1.162-2(b)(1), Income Tax
Regs. If a trip is primarily personal in nature, the travel
expenses are not deductible even if the taxpayer engaged in some
business activities at the destination. Id. Whether travel is
related primarily to the taxpayer's trade or business or is
primarily personal is a question of fact. Sec. 1.162-2(b)(2),
Income Tax Regs. The amount of time during the period of the
trip that is spent on personal activity, compared to the amount
of time spent on activities directly relating to the taxpayer's
trade or business, is an important factor in determining whether
the trip is primarily personal. Id. The taxpayer must prove
that the trip was primarily related to the trade or business.
Rule 142(a).
At trial, petitioners presented evidence indicating that
Mrs. Rezazadeh spent 50 of the 60 days she was in Bogota,
including weekends and holidays, doing research, which included
collecting, studying, organizing, and tabulating over 700 pages
of material. While Mrs. Rezazadeh did spend some time visiting
relatives while she was in Bogota, the Court is satisfied that
her trip to Bogota was primarily for business and not personal
purposes. Accordingly, petitioners are entitled to deduct those
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