- 12 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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