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traveling expenses relating to her trip to Denmark in May of
1994. Petitioner is therefore allowed a deduction for items 1
through 4 on appendix C, which total $363.87.8
With respect to her second trip to Denmark in 1994,
petitioner left from Seattle, Washington, on August 25 and
returned on September 4. Her trip thus spanned 11 days. Since
the trip exceeded the 7-day threshold set forth in section
274(c)(2)(A),9 we must determine whether the portion of the time
not allocable to petitioner’s trade or business constituted 25
percent or more of the total time of her trip.
The regulations specify that the total time traveling
outside the United States shall be allocated on a day-by-day
basis between days of business activity and days of nonbusiness
activity. See sec. 1.274-4(d)(2), Income Tax Regs. We therefore
must allocate each of the 11 days which petitioner spent on the
trip between these categories.10 The 2 days which petitioner
spent traveling to and returning from Denmark are considered
8 We note that petitioner did not introduce evidence as to
the cost of her travel to and from Denmark with respect to this
first trip, nor did she claim a deduction therefor.
9 In analyzing whether the travel time exceeded the 7-day
threshold provided in sec. 274(c)(2)(A), the day of departure is
not considered. See sec. 1.274-4(c), Income Tax Regs. Thus, for
purposes of sec. 274(c)(2)(A), petitioner’s trip lasted 10 days.
10 For purpose of analyzing the 25-percent test under sec.
274(c)(2)(B), the day of departure is included in the
calculation. See sec. 1.274-4(c), Income Tax Regs.
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