- 7 - record, we find that the delegation fee also covered lodging and travel within China. Neither the meals, lodging, or travel expenses covered by the delegation fee have been separately accounted for, as required by section 1.274-5T(b)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). Thus, these amounts are not deductible. While we also believe that some portion of the delegation fee likely represented a fee for attending the conference, there is no evidence in the record from which we might discern that portion, as distinguished from amounts subject to section 274(d)'s limitations. Accordingly, the entire fee is disallowed under section 274(d). Petitioner claimed a deduction for job-hunting expenses in the amount of $2,372.96. Respondent argues that the trips were primarily personal in nature. Petitioner took five trips during the year in issue during which she interviewed for positions in the health field. On all the trips, she stayed with colleagues or friends. The first trip was to San Francisco. She had a 1- day interview and stayed in San Francisco from March 14 through March 17. The second trip was to Beckley, West Virginia. Petitioner had a 1-day interview and stayed in Beckley from July 1 to July 6. Petitioner has family in West Virginia. The third trip was to Los Angeles, California. Petitioner again had a 1-day interview and stayed in Los Angeles from July 6 to July 11. The fourth trip was to Los Angeles, beginning November 27.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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