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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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