- 5 -
and other sites of interest, a far greater proportion of her time
was spent visiting hospitals and medical clinics accompanied by
Chinese health officials or participating in the formal
presentation of papers. Visiting medical facilities is not
personal recreation. On the contrary, we believe it bears a
direct relation to petitioner's work as an educator in the public
health field and is accordingly an ordinary and necessary
business activity with respect to petitioner. Consequently, her
travel to China and participation in the Conference activities
were primarily for business reasons within the meaning of the
regulations. As a result, we conclude that the following
expenses claimed by petitioner were "ordinary and necessary"
within the meaning of section 162(a): airfare to China, the
Conference fee ("delegation fee"), visa fee, books regarding
China, travel insurance, slides for presentations, tips,
breakfast, taxi, customs fees, parking, three meals, and a
beverage. Petitioner also claimed several additional expenses
with respect to the China trip that were purely personal or
living expenses which are not deductible under section 262(a).
Respondent's disallowance of these expenses is sustained.
Respondent has also challenged the China trip expenses on
the grounds that they have not been substantiated in accordance
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