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not an employee of petitioner. Accordingly, no deduction
attributable to expenses incurred on his behalf is allowed. See
sec. 274(m)(3)(A); sec. 1.274-2(g), Income Tax Regs.
While petitioner has satisfied the substantiation
requirements of section 274(d) with respect to a number of her
foreign traveling expenses, section 274(c) must also be addressed
given that these expenses relate to travel outside the United
States. Section 274(c)(1) provides that no deduction (otherwise
allowable under section 162) shall be allowed for that portion of
the expenses attributable to travel outside the United States
which, under regulations prescribed by the Secretary, is not
allocable to the taxpayer’s trade or business. See also sec.
1.274-4(a), Income Tax Regs. The provisions of section 274(c)(1)
are applicable only if (a) the travel outside the United States
exceeds 1 week and (b) the portion of the time of such travel
which is not attributable to the pursuit of the taxpayer’s trade
or business is 25 percent or more of the total time of such
travel. See sec. 274(c)(2); sec. 1.274-4(b), Income Tax Regs.
The record reflects that petitioner’s travel to Denmark in
May of 1994 spanned a 6-day period from May 18 to May 23. We
therefore find that petitioner’s travel overseas during this
period did not exceed 1 week. As the exception under section
274(c)(2)(A) applies, section 274(c)(1) does not impose an
additional restriction on petitioner’s ability to deduct
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