Betty J. Shackelford - Page 17

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          Commissioner, 33 T.C. 838, 841-843 (1960).  While we agree that             
          petitioner wanted her daughter to come to California and work for           
          her, petitioner has failed to establish that the moving expenses            
          were incurred primarily for business purposes and that personal             
          considerations were distinctly secondary.  We, therefore, uphold            
          respondent's disallowance of any deduction for moving expenses.             
               Petitioner claimed a deduction in the amount of $399.88 for            
          payment of a deposit and the first month's rent for an apartment            
          for Renata in California.  Petitioner contends that these                   
          expenditures were an agreed upon condition of Renata's employment.          
          Renata was barely able to pay her last month's rent and had no              
          money to rent an apartment in California.  Petitioner contends that         
          these expenditures were therefore necessary to facilitate Renata's          
          relocation to California and her employment with petitioner.                
          Petitioner has failed to establish that these expenditures were             
          incurred primarily for business reasons and not primarily motivated         
          by personal considerations, and we uphold respondent's disallowance         
          of a deduction for them.  Henry v. Commissioner, supra; Larrabee v.         
          Commissioner, supra.                                                        
               Petitioner claimed a deduction for a check in the amount of            
          $231 payable to Maynard & McDonald and for a check in the amount of         
          $376.64 payable to Gold Country Financial, Inc.  Petitioner argues          
          that the expenditures were for health insurance for Renata, which           
          petitioner contends was an agreed upon condition of Renata's                
          employment.  The check written to Gold Country Financial, Inc.,             




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