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In addition to the strict substantiation requirements of
section 274(d), a deduction for foreign travel is subject to the
allocation requirements of section 274(c). See sec. 1.274-4(a),
Income Tax Regs. Thus, section 274(c) generally requires the
proration of foreign travel expenses between business and
nonbusiness expenses.
For petitioner’s trips to Istanbul and Peru, to the extent
that the strict substantiation rules of section 274(d) apply,
petitioner has not adequately substantiated any of his claimed
deductions. See sec. 274(d); sec. 1.274-5T(a), Temporary Income
Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985); see also sec. 6001;
sec. 1.6001-1(a), Income Tax Regs.
For petitioner’s trip to Italy, petitioner was reimbursed
for a portion of his airfare. Beyond this item, petitioner did
not provide any documentation showing an allocation between his
personal and “business” expenses for the trip as required by
section 274(c).
It is clear from the record that petitioner’s trip to
Portland for a convention was directly related to his occupation
as a professor. Petitioner stated that he was not reimbursed by
the college for his airline ticket “because there was a
technicality in the procedure.” Paragraph (C)(2)(c) of the
college’s Travel Reimbursement Policy states, in pertinent part:
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Last modified: May 25, 2011