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Similarly, with regard to the other travel expenses,
petitioner has no records indicating the business purpose of the
trips. Petitioner testified that the trip to Buffalo, New York,
was to meet a “potential customer”, but there is no indication of
any business discussions. While in preparation for the trial
petitioner wrote the name Davis Evans on the Columbus, Ohio,
hotel receipt, there again is no indication of any business
discussions. These records do not satisfy the adequate record
requirements of section 274, and we sustain respondent’s
disallowance of the travel expense deductions.6
Turning to the deductions claimed for “utilities”, as we
understand, petitioners claim that petitioner used a portion of
their home for her business. For the 2000 taxable year
petitioners also claimed a deduction for business use of their
home. Section 280A(a) prohibits any deduction “with respect to
the use of a dwelling unit which is used by the taxpayer * * * as
a residence.” A portion of a dwelling may be exempted from
section 280A(a) if it is exclusively used on a regular basis “as
the principal place of business for any trade or business of the
taxpayer”. Sec. 280A(c)(1).
6 Petitioner also introduced into evidence pages of a January
and December 2000 calendar and what she describes as customer
sheets containing the names, addresses, and telephone numbers of
potential customers. Neither indicated whether she had any
business meetings with these customers during her travels.
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