Karan M. Hintze - Page 13

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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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