Karan M. Hintze - Page 16

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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                 

               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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