Karan M. Hintze - Page 12

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          (2) the dates of departure and return and the number of days                
          spent on business; (3) the place of destination by name of city             
          or town; and (4) the business reason or expected business benefit           
          from the travel.  See sec. 274(d); sec. 1.274-5T(b)(2), Temporary           
          Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).                        
                    a.   Expenses Not Subject to Section 274                          
               As a preliminary matter, we note that a number of the                  
          expenses included by petitioner under the category of traveling             
          expenses do not constitute traveling expenses for purposes of               
          section 274(d).  The most significant of these items are the                
          expenses which petitioner incurred for renting the hotel                    
          conference rooms in which to conduct her seminars.6  The expenses           
          which we find are not subject to the substantiation requirements            
          of section 274(d) total $1,711.99 and are enumerated in appendix            
          A.7  Petitioner is entitled to a deduction for such amounts.                
                    b.   Domestic Travel                                              
               With respect to deductions claimed for traveling expenses              
          within the United States, we find that petitioner has satisfied             
          the substantiation requirements of section 274(d) with respect to           

               6  Petitioner charged a substantial fee for attending the              
          seminars.  We do not view the direct costs of conducting the                
          seminars as constituting a traveling expense under sec. 274(d)(1)           
          or an item generally considered to constitute entertainment under           
          sec. 274(d)(2).  See sec. 1.274-2(b)(1), Income Tax Regs.                   
               7  These expenses are in addition to the $347 of parking               
          expenses conceded by respondent.                                            

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