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expenses are incurred 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.; Holswade v. Commissioner, 82
T.C. 686, 698, 701 (1984). The amount of time during the period
of the trip that is spent on personal activity, compared to the
amount of time spent on activities directly relating to the
taxpayer's trade or business, is an important factor in
determining whether the trip is primarily personal. The taxpayer
must prove that the trip was primarily related to the trade or
business. Rule 142(a). Petitioners failed to establish that
petitioner spent more time on his air racing activity than on
personal endeavors during his days in San Diego.5
5 As the Court understands the evidence presented,
petitioner attributed the entire time he was not flying
commercially to time in San Diego that was devoted exclusively to
his trade or business activities in San Diego, with no allowances
made for personal time petitioner spent with his wife and family
or other personal endeavors. There is also some indication that
the records of American Airlines reflected that petitioner was
flying for the airline on certain days; yet, petitioner claimed
these same days in San Diego attending to his trade or business
(continued...)
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