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deductions on the Schedules A for 1997 and 1998. Further, before
departing for such trips, Mr. Evan did not make any effort to
determine whether the person with whom he desired to speak
regarding job opportunities would be available.
Petitioners did not own or operate a business during the
years in issue and were not self-employed during that period.
On October 23, 2000, respondent sent petitioners a notice of
deficiency for 1997 and 1998, disallowing, inter alia, the
itemized deductions for unreimbursed employee expenses and the
Schedule C business expenses for 1997 and 1998. Respondent
explained that the unreimbursed employee expenses “did not meet
the requirements for allowable job-hunting expenses” and “it has
not been established that these [Schedule C business expenses]
were ordinary and necessary trade or business expenses or
expended for the purpose designated.”
On January 22, 2001, petitioners mailed a petition to the
Court disputing the disallowances.1
On February 12, 2001, petitioners had a fire at their
residence, resulting in damages of over $500,000. Although
petitioners searched through the rubble to try to find the
records for 1997 and 1998, none were found. Petitioners did not
1 In the notice of deficiency respondent also disallowed a
portion of the medical expenses. Petitioners did not raise this
issue in the petition, and we deem it conceded. See Rule
34(b)(4).
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