Derk O. and Julia K. Pehrson - Page 5

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          Income Tax Regs.  If a trip is primarily personal in nature,                
          expenses are not deductible even if the taxpayer engaged in some            
          business activities at the destination.  Id.  Whether travel is             
          related primarily to the taxpayer's trade or business or is                 
          primarily personal is a question of fact.  Sec. 1.162-2(b)(2),              
          Income Tax Regs.; see also Holswade v. Commissioner, 82 T.C. 686,           
          698, 701 (1984).  The amount of time during the period of the               
          trip that is spent on personal activity, compared to the amount             
          of time spent on activities directly relating to the taxpayer's             
          trade or business, is an important factor in determining whether            
          the trip is primarily personal.  Holswade v. Commissioner, supra.           
          The taxpayer must prove that the trip was primarily related to              
          the trade or business.  Rule 142(a).                                        
               Petitioners contend that the Orlando trip was primarily                
          related to petitioner husband's business as a real estate broker,           
          and, therefore, the $905 automobile rental expense should be                
          deductible on Schedule C of their return as a trade or business             
          expense.  Petitioners contend further that any sightseeing and              
          other personal activities engaged in during the trip were purely            
          incidental.  Respondent contends that the Orlando trip was not              
          primarily related to petitioner husband's trade or business as a            
          real estate broker, and, therefore, the automobile rental expense           
          is not deductible.                                                          







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