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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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