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with section 274(d).3 On this record, we believe that petitioner
has, by means of the receipts, Conference itinerary, and other
Conference materials introduced into evidence, substantiated all
of the expenses found to be ordinary and necessary above, see
sec. 1.274-5T(c)(3)(i), Temporary Income Tax Regs., 50 Fed. Reg.
46020 (Nov. 6, 1985), except the delegation fee. Under section
274(d), one of the elements that the taxpayer must prove with
respect to an expenditure for travel away from home is the
Amount of each separate expenditure for traveling away
from home, such as cost of transportation or lodging,
except that the daily cost of the traveler’s own
breakfast, lunch, and dinner and of expenditures
incidental to such travel may be aggregated, if set
forth in reasonable categories, such as for meals, for
gasoline and oil, and for taxi fares. [Sec. 1.274-
5T(b)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg.
46014 (Nov. 6, 1985).]
Petitioner indicated on the Conference materials she introduced
into evidence that the delegation fee covered some meals during
the Conference. We also note that although petitioner spent 12
days in China in connection with the Conference, there is no
stated expense for lodging. Likewise, although Conference events
occurred in four different cities, there is no stated expense for
travel within China. Given that the delegation fee was $3,400,
it is obvious that it covered more than meals. Based on the
3 Respondent has not challenged the expenses of the China
trip under sec. 274(c), (h), (m)(2), or (n). We consequently do
not address the extent to which these provisions may limit
petitioner’s deductions.
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