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travels does not subvert their business purpose. On the basis of
the record, we find that petitioner spent most of her time in
Greece and in Southeast Asia participating in the U.C. Extension
courses.5
Petitioner, however, has not established that the $240
expense she incurred for hotel accommodations before the
Legendary Greece course began is attributable to business
activity. Petitioner testified that she arrived 2 days early in
Greece so that she would have an opportunity to recover from jet
lag before the course began. We find this expense to be
attributable to personal activity.
We thus hold that petitioner's education and travel
expenses, with the exception of the $240, are ordinary and
necessary business expenses within the meaning of section 162.
In addition to being subject to the requirements of section
162 and the provisions under section 274 already discussed, a
taxpayer's deductions for certain travel expenditures are subject
to other provisions of section 274. Respondent, however, has not
challenged petitioner's travel expenses under the substantiation
requirements of section 274(d) or under the limitation on meal
5 Although respondent does not contend that petitioner’s
travel expenses are subject to the provisions of sec. 274(c), the
regulations issued under this section tend to support our
determination that petitioner was primarily engaged in business
activity during the time she spent in Greece and in Southeast
Asia. See sec. 1.274-4(d)(2), Income Tax Regs.
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