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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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