Gregory A. Maslow and Marina Maslow - Page 9

          insurance activities by traveling to the homes of his customers.            
          The record further indicates that (1) petitioner occasionally, but          
          not regularly, met other insurance agents at his residence, and (2)         
          petitioner had an outside office for 3 months during 1992.                  
               Because petitioner did not satisfy the requirements of section         
          280A, we sustain respondent's disallowance of petitioners' $6,813           
          claimed home-office expenses.  See Commissioner v. Soliman, 506             
          U.S. 168 (1993).                                                            
               B.  Travel Expenses                                                    
               Respondent disallowed $7,220 of the claimed $9,923 travel              
          expenses, determining that petitioners deducted, rather than                
          included in income, the $7,220 travel award by Kentucky Central             
          Life Insurance Co. referred to supra. Respondent allowed the                
          balance of the claimed $9,923 travel expenses ($2,703) as                   
          automobile travel expenses incurred in connection with petitioner's         
          insurance business.                                                         
               Petitioner claims that $7,220 of the claimed travel expenses           
          relates to trips to Israel (February 13-16, 1992), Russia (May 16-          
          20, 1992), Brussels (September 15-24, 1992), and Luxembourg                 
          (November 17, 1992), in connection with the startup of his export           
          business and has no connection with the travel award by Kentucky            
          Central Life Insurance Co.  Even if we accept petitioner's claim,           
          nonetheless, petitioner failed to substantiate the costs of those           
          trips.  See sec. 274(d)(1).  Moreover, petitioner did not file a            
          Schedule C for his export business activities.                              

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