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relating to the taxpayer's trade or business, is an important
factor in determining whether the trip is primarily personal.
See sec. 1.162-2(b)(2), Income Tax Regs.
Petitioner claims that she traveled to San Diego,
California, and Mexico during 1991 in an effort to purchase less
expensive garments and materials for the manufacture of garments.
During 1992, petitioner contends she traveled to Los Angeles to
attend a clothing market for the wholesale purchase of various
garments for resale in the retail market. Petitioner also claims
that she traveled to New Orleans, Louisiana, during 1992 for the
purpose of attending the Black Expo, at which she maintained a
booth and dispensed information and merchandise to attendees
there. The testimony at trial indicated that another purpose for
attending the Black Expo was to develop a mail-order business for
Special O. Petitioner contends further that she made another
garment and fabric-purchasing trip during 1993 to San Diego,
California, and Yuma, Arizona.
Petitioner testified that, during her 1991 trip to Mexico,
she visited Tijuana and purchased jewelry and a purse, but she
produced no evidence to show that these items were purchased for
a business purpose rather than for her own personal use.
Petitioner admitted that the majority of her 1992 trip to New
Orleans was spent visiting relatives at Baton Rouge, Louisiana.
Petitioner also admitted that, during the Black Expo, she stayed
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