- 21 -
expense was incurred; and (3) the business purpose for which such
expense was incurred.
At trial, the only evidence petitioners presented was a copy
of Mrs. Rezazadeh's round-trip airline ticket to Bogota. The
ticket indicated the dates and destination of travel and the
$901.28 cost of the round-trip flight. Petitioners have properly
substantiated their entitlement to a travel expense deduction for
the amount of the flight. With respect to the other expenses
claimed, petitioners have not satisfied the strict substantiation
requirements of section 274(d) and, therefore, are not entitled
to deduct the remaining travel expenses claimed.5
With respect to the third issue, petitioner has authored and
published several books, conducting this activity in a portion of
5
Sec. 274(c)(1) provides generally that, in the case of an
individual who travels outside the United States away from home
in pursuit of a trade or business or an activity under sec. 212,
no deduction shall be allowed under sec. 162 or sec. 212 for that
portion of the expenses of such travel otherwise allowable under
such sections that, under regulations prescribed by the
Secretary, is not allocable to such trade or business or to such
activity. Sec. 274(c)(2) provides certain exceptions to the
applicability of sec. 274(c)(1), one of which is where the
portion of the time of travel outside the United States away from
home that is not attributable to the taxpayer's trade or business
or a sec. 212 activity is less than 25 percent of the total time
on such travel. In this case, the travel time spent by Mrs.
Rezazadeh on activities not attributable to petitioner's trade or
business was considerably less than 25 percent of her total
travel time. Moreover, the record does not show that any of the
expenses incurred by Mrs. Rezazadeh not attributable to
petitioner's trade or business would have otherwise been
allowable under sec. 162. Consequently, the provisions of sec.
274(c)(1) are not applicable to this issue.
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