Rev. Rul. 78-23

Section 274(h) of the Internal Revenue Code of 1954 limits the amount of allowable deductions of an individual for attending foreign conventions. For purposes of section 274(h), the Commonwealth of Puerto Rico is treated as a possession of the United States. See section 7701(c). Therefore, the limitations imposed by section 274(h) on deductions for attending foreign conventions are not applicable to expenses incurred by individuals in attending conventions in the Commonwealth of Puerto Rico.