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with her relatives in Baton Rouge and rented a van to drive to
New Orleans each day for the expo. With respect to the 1993 trip
to Yuma, Arizona, petitioner claims she visited several fabric
stores but was unable to provide the names or locations of any
such stores or produce any evidence that she made purchases at
such stores.
The Court is not satisfied that petitioner, on behalf of
Special O, engaged in any business travel during 1991 or 1993.
Moreover, even if the Court were to hold that petitioner made
business trips (as opposed to trips for personal pleasure) to
Mexico, San Diego, and Yuma during 1991 and 1993, or engaged in
any other business travel during those years, the strict
substantiation requirements of section 274(d) have not been
satisfied with respect to any such travel. On the entire record,
the Court holds that no travel expenses are deductible by Special
O for 1991 or 1993.
The Court is satisfied, however, that petitioner attended
the Black Expo in New Orleans during 1992 for a proper business
purpose in connection with Special O. However, the Court is
likewise convinced that the primary purpose for petitioner's trip
in this regard was the personal purpose of visiting relatives in
Baton Rouge. Thus, only those expenses properly allocable to the
business of Special O would be deductible but the travel to and
from New Orleans would not be deductible.
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