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expense deductions for (1) travel expenses of $782, and (2) meal
and entertainment expenses of $60.
In August 1997, petitioner traveled to Washington, D.C., to
attend a college fraternity convention. Petitioner incurred
expenses in relation to the convention of $689.17 for travel and
$120 for meals. Pursuant to section 274(n), only 50 percent of
meal and entertainment expenses is allowed as a deduction. Thus,
of the $120 of expenses incurred by petitioner, only $60 was
claimed as a deduction.
Petitioner testified that the expenses relating to the
fraternity convention were ordinary and necessary business
expenses because he solicited business while attending the
convention and cut the hair of members of the fraternity.
Further, petitioner testified to the many activities offered at
the convention, none of which pertain to the barber shop
business.
We believe the expenses incurred by petitioner relating to
the fraternity convention are not “directly connected with or
pertaining to” petitioner’s barber shop Schedule C business.
Sec. 1.162-1(a), Income Tax Regs. Moreover, we believe the
convention-related expenses to be personal, and, therefore, not
deductible under section 262(a). The fact that petitioner may
have derived some incidental or indirect benefit to his business
by attending the convention is not sufficient to satisfy the
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