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WALLISER v. COMMISSIONER

Docket No. 2368-77.

72 T.C. 433 (1979)

JAMES B. WALLISER AND CAROL SUE WALLISER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 7, 1979.

Attorney(s) appearing for the Case

Ira W. Silverman and Donald J. Forman, for the petitioners.

Deborah A. Butler, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency of $323 in petitioners' income tax for the taxable year 1973 and a deficiency of $252.45 in petitioners' income tax for the taxable year 1974. At issue is whether amounts expended by petitioners for foreign travel are deductible as ordinary and necessary business expenses under section 1621 and, if so, whether the requirements of section 274 have been satisfied.

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