Eugene A. Beck, et al. - Page 30




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          vacation, primarily for the recreation and pleasure of the                  
          family.  The expenses are not deductible.                                   
                    4.  Travel Expenses and Entertainment Expenses                    
                         a.  Las Vegas Expenses                                       
               Beck's Liquors deducted travel expenses Mr. Beck incurred              
          traveling to Las Vegas, and expenses incurred for the yearly trip           
          to the cabin.  Under section 162(a)(2), a taxpayer is allowed to            
          deduct ordinary and necessary travel expenses paid while away               
          from home in the pursuit of business.  Commissioner v. Flowers,             
          supra at 470; Walliser v. Commissioner, 72 T.C. 433, 437 (1979).            
          Where a taxpayer travels to a destination for both business and             
          personal activities, travel expenses to and from the destination            
          are deductible only if the trip is related primarily to the                 
          taxpayer's business.  If the purpose of the trip is primarily               
          personal, the travel expenses to and from the destination are not           
          deductible even though the taxpayer engages in some business                
          activities at the destination.  Duncan v. Commissioner, 30 T.C.             
          386, 390-391 (1958); sec. 1.162-2(b)(1), Income Tax Regs.                   
          Whether a trip is related primarily to the taxpayer's business or           
          is primarily personal is a question of fact.  Commissioner v.               
          Flowers, supra; sec. 1.162-2(b)(1), Income Tax Regs.  A casual              
          connection to one's business does not make the cost of the trip a           
          business expense.  Ballantine v. Commissioner, 46 T.C. 272, 279-            
          280 (1966).                                                                 






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