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not met the stringent requirements of section 274(d), and they
are not entitled to a deduction for travel, meals, and
entertainment.
Petitioners also took two “research” trips in 1994.
Petitioners went to Alaska and Mexico; these trips cost $3,296
and $1,319, respectively. On petitioners’ return it is explained
that the purpose of these trips was to “obtain on-site data and
photos for in-progress development of screenplay project.” Mr.
Richards testified that Mrs. Richards went along on the trips as
his photographer. The costs included airfare for both
petitioners, cruise fare, escorted side tours, travel insurance,
and incidental expenses. Mr. Richards testified that they went
to Mexico to see a comedienne, a prospect for whom he thought he
could write material. Mr. Richards did not state whether he ever
wrote material for the comedienne.
The expenses for these research trips also fall under the
requirements of section 274(d), and we find that petitioners have
failed to satisfy such requirements. Petitioners have proven
that they incurred these expenses, but they have not established
that these expenses were sufficiently connected to a trade or
business. Trips consisting of cruises, sightseeing, and tours
are essentially for personal enjoyment, and petitioners have not
proven otherwise. Therefore, respondent is sustained on this
issue.
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