- 15 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011