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expenses totaling $1,710.93. These expenses are enumerated in
appendix B.
c. Foreign Travel
Most of the deduction claimed by petitioner for traveling
expenses pertains to expenses incurred for travel overseas.
During the summer of 1994, petitioner conducted two seminars in
Denmark to promote her micropigmentation instruction courses.
The first was held at a hotel in Copenhagen, Denmark, on August
29, and the second was held in Alborg, Denmark, on August 31.
Petitioner embarked on her trip to Denmark on August 25, and she
returned on September 4. In order to conduct preliminary work
for the seminars and to establish contacts, petitioner traveled
to Denmark in May of 1994.
With respect to the traveling expenses incurred by
petitioner during her trips to Denmark, we find that petitioner
has satisfied the heightened substantiation requirements of
section 274(d) with respect to those expenses enumerated in
appendix C. These expenses total $3,505.32.
Among the expenses which we find petitioner did not
substantiate under section 274(d) are the airfare and other
expenses attributable to Rick Schultsmeier. Petitioner testified
that Mr. Schultsmeier accompanied her on the trip to assist her
in transporting the equipment and materials which petitioner
needed to conduct her seminars. Mr. Schultsmeier, however, was
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