Susan E. Shores - Page 11

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          414 (10th Cir. 1983).  If travel expenses are incurred for both             
          business and other purposes, the expenses are deductible only if            
          the travel is primarily related to the taxpayer's trade or                  
          business.  Sec. 1.162-2(b)(1), Income Tax Regs.  If a trip is               
          primarily personal in nature, the travel expenses are not                   
          deductible even if the taxpayer engages in some business                    
          activities at the destination.  Id.  Whether travel is primarily            
          business related or personal is a question of fact.  Sec. 1.162-            
          2(b)(2), Income Tax Regs.                                                   
               Petitioner claimed a deduction for travel expenses in the              
          amount of $1,940.  Petitioner presented copies of her credit card           
          statements and marked the items associated with her travel                  
          expenses including airfare, rental car fees, and lodging.                   
          Petitioner testified that her trips to Minneapolis, Seattle, and            
          Boston were in response to immediate concerns involving au pairs            
          and families at those locations and gave specific information               
          regarding the nature of the concerns associated with each trip.             
               Petitioner also deducted travel expenses for trips to St.              
          Croix, Puerto Rico, Disneyland, and Las Vegas.  The fact that a             
          taxpayer engaged in business during a portion of the trip is not            
          sufficient to entitle the taxpayer to deduct travel expenses                
          absent a showing that business was the primary motive for the               
          trip.  Reed v. Commissioner, 35 T.C. 199 (1960); Levine v.                  
          Commissioner, T.C. Memo. 1987-413; sec. 1.162-2(b)(1) Income Tax            






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