- 16 - 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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