Education v. Personal Expenses:
a. people try to pass off conventions and seminars (vacations) as educational expenses
i. 1.162-2(d): conventions—is there a “sufficient relationship” b/w the convention and the trade or business?
1. 2 standards for whether or not convention is deductible:
a. referral standard,
i. the taxpayer claims deductibility for activities that generate business
b. agenda standard
i. focuses on the relationship of the agenda for the seminar or conference to the taxpayer’s trade or business, both to subject matter and time allotted to actual business
b. Even if a deduction for a convention is allowed, travel expenses are still to be tested under 1.162-2(b)(2)
i. 1.162-5: the convention regulation qualifies as deductions only expenses for meals, lodging, registration, and materials—educational expenses
ii. 274(n) still spanks meals, and 274(h) is stricter in the convention and international context
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