- 12 - (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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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