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for both business and other purposes, such expenses are
deductible only if the travel is primarily related to the
taxpayer's trade or business. If a trip is primarily personal in
nature, expenses incurred are not deductible even if the taxpayer
engaged in some business activities at the destination. Id.
Whether travel is related primarily to the taxpayer's trade
or business or is primarily personal is a question of fact. Sec.
1.162-2(b)(2), Income Tax Regs.; see also Holswade v.
Commissioner, 82 T.C. 686, 698, 701 (1984). The amount of time
during the period of the trip that is devoted to personal
activity, compared to the amount of time devoted to activities
directly relating to the taxpayer's trade or business, is an
important factor in determining whether the trip is primarily
personal. Sec. 1.162-2(b)(2), Income Tax Regs. The taxpayer
must prove that the trip was primarily related to the trade or
business. Rule 142(a).
Petitioner submitted no documentary evidence to support the
claimed deduction for travel, meals, and entertainment expenses.
Petitioner admitted that he both conducted business and visited
family on his trips to China. The evidence submitted by
petitioner in support of the travel, meals, and entertainment
expenses is insufficient to satisfy the strict substantiation
requirements of section 274(d). Furthermore, the Court is not
satisfied that petitioner's trips to China were primarily related
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