Reza and Connie M. Rezazadeh - Page 21

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          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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