James H. Shelton, Deceased, and Eve Shelton - Page 12

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          with petitioner's Schedule C business.  Petitioners traveled to                    
          popular cities and visited what would normally be considered                       
          tourist attractions.  On their trips petitioners visited with                      
          relatives who lived in the area.  When questioned at trial,                        
          petitioner was unable to state whether he sold any books as a                      
          result of any of his travels.  Petitioners have failed to                          
          convince us of a business nexus between petitioners' travels and                   
          the sale of petitioner's book, and, we fail to see how petitioner                  
          expected his travels to produce commensurate benefits for the                      
          business, especially in light of the haphazard manner in which he                  
          visited the bookstores.                                                            
                Moreover, petitioners have provided no evidence to establish                 
          that travel expenses incurred by petitioner's wife had a "bona                     
          fide business purpose".  See sec. 1.162-2(c), Income Tax Regs.;                    
          sec. 262.  In addition, petitioners have not presented us with                     
          sufficient evidence to satisfy the substantiation requirements                     
          imposed by section 274(d).  Accordingly, we sustain respondent's                   
          adjustment to petitioners' travel expense deduction.                               
          B. Rent Expense Deduction                                                          
                On the Schedule C for 1992, petitioner claimed a rent                        
          expense deduction in the amount of $2,082.  Respondent now                         
          concedes that petitioner is entitled to a rent expense deduction                   
          but only in the amount of $1,772.35.                                               
                Section 162 specifically allows a deduction for rental                       
          expenses.  Sec. 162(a)(3).  As indicated above, deductions are a                   




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