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the business purpose of the expense or other item, and
(D) the business relationship to the taxpayer of
persons entertained, using the facility or property, or
receiving the gift. * * *
Thus, under section 274(d), deductions for automobile expenses,
travel expenses, and meals and entertainment expenses may not be
estimated. Instead the taxpayer must provide adequate records or
corroborate testimony with other evidence.
If a taxpayer travels to a destination and, while at such
destination, engages in both business and personal activities,
traveling expenses to and from such destination are deductible
only if the trip is primarily related to the taxpayer's trade or
business. See sec. 1.162-2(b)(1), Income Tax Regs. If a trip is
primarily personal in nature, traveling expenses to and from the
destination are not deductible even if the taxpayer engaged in
some business activities at the destination. See id. However,
expenses while at the destination that are properly allocable to
the taxpayer's trade or business are deductible even though the
traveling expenses to and from the destination are not
deductible. See id.
Whether travel is related primarily to the taxpayer's trade
or business, or is primarily personal, is a question of fact.
See sec. 1.162-2(b)(2), Income Tax Regs.; see also Holswade v.
Commissioner, 82 T.C. 686, 698, 701 (1984). The amount of time
during the period of the trip that is spent on personal activity,
compared to the amount of time spent on activities directly
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