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business days. See sec. 1.274-4(d)(2)(i), Income Tax Regs. In
addition, any day during which the principal activity was the
pursuit of petitioner’s trade or business constitutes a business
day. See sec. 1.274-4(d)(2)(iii), Income Tax Regs. The business
activities in which petitioner engaged while in Denmark included
not only preparing for and conducting the seminars, but also
training the individuals who sought petitioner’s instruction
courses. One of petitioner’s clients testified that a typical
training session following a seminar took anywhere from 3 to 5
days.11 Accordingly, in addition to the 2 days which petitioner
spent preparing for and conducting the seminars, we find that
petitioner spent at least an additional 5 days training clients
whom she obtained through the two seminars and through her
efforts during her prior trip to Denmark in May. As at least 9
days of petitioner’s 11-day trip were devoted to the pursuit of
petitioner’s trade or business, the exception provided by section
274(c)(2)(B) applies. Section 274(c)(1) therefore does not
impose an additional limitation on the deductibility of
petitioner’s traveling expenses relating to her second trip to
Denmark during 1994. Accordingly, petitioner is entitled to a
deduction for items 5 through 30 in appendix C, which total
$3,141.45.
11 This testimony was provided by Beverly Violette, an
individual who took a micropigmentation instruction course from
petitioner in 1995. We find her testimony probative of the
general nature of the instructional courses which petitioner
offered during the prior year.
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