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there are circumstances which prevented the taxpayer from incurring
the expenses of moving within the 1-year period. Sec. 1.217-
2(a)(3), Income Tax Regs. Costs of storage are not deductible
unless incurred in transit, which is defined as within any
consecutive 30-day period after the goods are moved from the
taxpayer's former residence and before delivery at the new
residence. Sec. 1.217-2(b)(3), Income Tax Regs.
Petitioners moved from Cleveland to Kalamazoo in early 1987,
when Mr. Martin began a new job. Petitioners claim a $3,273
deduction for moving expenses that were incurred in 1989. We do
not believe that these expenses were reasonably proximate in time
to the commencement of Mr. Martin's new employment in Kalamazoo.
Petitioners claim that there were circumstances beyond their
control which dictated the amount of time for the move: (1) The
local real estate market was very tight and no houses were
available, and (2) business related job activities required all of
Mr. Martin's time. We have considered these arguments and reject
them. There was no showing that a suitable house in the Kalamazoo
area could not have been acquired within a 1-year period, and
although Mr. Martin's job activities might have required a
substantial portion of his time, there was no showing that Mrs.
Martin could not have looked for suitable housing. Further, the
expenses of moving the goods from storage to petitioners' newly
refurbished house were not incurred in transit, but rather are
storage related expenses. Therefore, respondent's determination
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