-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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