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At trial, petitioner husband admitted that the portion of
the trip to Orlando was not related to his trade or business of
real estate sales but, rather, was related to petitioner wife's
employment. Petitioner wife's employer reimbursed petitioners
for the cost of sending petitioner wife to the seminar in
Orlando. The total length of the trip was 15 to 17 days.
Petitioner husband admitted further that only 3 days of the trip
were attributable to his business activities in Harrisburg, and 5
days were attributable to petitioner wife's seminar in Orlando.
The remainder of the trip was spent traveling. When questioned
as to why he did not make a separate trip to Harrisburg,
petitioner husband responded that it was more economical for him
to combine the two destinations into one trip.
The amount of time spent on petitioner husband's business
activities was nominal in relation to the entire trip.
Furthermore, the date of the trip, as well as the travel route,
were determined primarily by petitioner wife's seminar in
Orlando. Petitioner husband had known for at least several
months prior to the trip that he needed to conduct business in
Harrisburg. He delayed the conduct of such business, however,
and chose to combine it with petitioner wife's seminar trip as a
matter of family convenience and economics.
On this record, the Court finds that petitioners' trip was
not primarily related to petitioner husband's business as a real
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