Susan E. Shores - Page 12

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          Regs.  Petitioner offered no further evidence with respect to the           
          business purpose of these trips other than her testimony that the           
          trips served an educational purpose for the au pairs.  We are not           
          satisfied that these trips were primarily related to petitioner's           
          trade or business.                                                          
               On the basis of this record, we conclude that petitioner is            
          entitled to a deduction for travel expenses associated with her             
          trips to Minneapolis, Seattle, and Boston.  Accordingly,                    
          petitioner is entitled to a deduction of $911.64 for travel                 
          expenses.                                                                   
               9.  Meals and Entertainment                                            
               A taxpayer may deduct meal and entertainment expenses if               
          they are directly related to the active conduct of the taxpayer's           
          trade or business.  Sec. 1.274-2(d)(1), Income Tax Regs.  The               
          deduction for meal and entertainment expenses generally is                  
          limited to 50 percent of the substantiated amount.  Sec. 274(n).            
               Petitioner claimed she incurred meal and entertainment                 
          expenses in the amount of $523.62.  Petitioner provided canceled            
          checks and copies of her credit card statements for restaurant              
          meals and groceries.  Petitioner testified that she incurred                
          expenses in entertaining au pairs and families either at                    
          restaurants or at her home.  We find petitioner's testimony                 
          credible and detailed with respect to the business purpose of the           
          meals and the business relationship of the individuals                      






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