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related to Mr. Zeidler's trade or business activity. The Court
agrees with respondent. Petitioners did not establish that Mrs.
Zeidler's accompaniment of her husband on these trips was in any
way related to or contributed to Mr. Zeidler's business. The
trip to North Carolina was during the Christmas season and
included a visit to Mrs. Zeidler's parents. There was no showing
that Mrs. Zeidler participated in any activity related to Mr.
Zeidler's trade or business. Petitioners failed to show any
business purpose for Mrs. Zeidler on the Birmingham, Alabama,
trip. The $909 expense is considered a personal expense and is
not deductible under section 262. Respondent, therefore, is
sustained on this issue.
Petitioners' 1990 income tax return was signed on
November 4, 1991, and was received by the IRS on November 8,
1991. Petitioners had obtained an automatic extension that
extended the filing period for their 1990 return to August 15,
1991. Petitioners signed their 1992 return on August 12, 1993;
however, respondent alleged on brief that the envelope in which
petitioners mailed their return to the IRS bore a postmark date
of August 24, 1993, and was received by the IRS on August 28,
1993. Petitioners also obtained an automatic extension to file
their 1992 return on or before August 15, 1993. Respondent
determined the addition to tax under section 6651(a)(1) for both
years. At trial, petitioners presented no evidence on this issue
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