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the travels were expressly required by her employer.
Accordingly, petitioners are not entitled to deduct the expenses
related to Mrs. Garcia’s European travels.
We next address whether the amount Mr. Garcia paid for
country club dues is deductible. Section 274 contains several
exceptions to the deductibility of ordinary and necessary
expenses incurred in carrying on a trade or business. Expenses
paid or incurred for membership in any club organized for
business, pleasure, recreation, or other social purpose are not
deductible. Sec. 274(a)(3). More specifically, expenses paid
for golf and country club dues are not deductible. Sec. 1.274-
2(a)(2)(iii)(a), Income Tax Regs. In addition, the legislative
history to section 274(a)(3) emphasizes that it is a strict
nondeductibility rule. See H. Rept. 103-111, at 646 (1993),
1993-3 C.B. 167, 222. No one, including golf professionals or
instructors, may deduct club dues. Congress explained that the
non-deductibility rule eased compliance with former law that
required determining whether the primary purpose of belonging to
the country club was personal. Id. Accordingly, petitioners are
not entitled to deduct $1,628 that they paid in 2000 for Mr.
Garcia’s membership in the Baywood Country Club.
We find that petitioners failed to establish that they were
entitled to deduct these disputed expenses as ordinary and
necessary expenses for their respective teaching positions.
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