-14- that they are nondeductible capital expenditures, to be added to the basis of the stock acquired. Wagner v. Commissioner, 78 T.C. 910, 915 (1982). Petitioners failed to show error in respondent's determination. Thus, we sustain respondent's disallowance of the deduction for investment expenses. Job-Search Expenses Petitioners claim entitlement to deduct in 1989 $9,213 in job- search expenses. Although respondent argued that petitioners failed to show the business purposes of these expenditures, Mr. Martin testified that when he realized that his position with Aero- Motive was in jeopardy, he began to look for other work. We believe him, but we do not find that the entire amount of job- search expenses that petitioners claim is deductible. A review of petitioners' receipts shows a number of items that are not ordinary and necessary expenses, as required by section 162(a). For instance, petitioners submitted receipts for the purchase of People magazine and the Enquirer, and for gifts to friends visited by petitioners. There is a $65 check payable to Video Land, with no notation as to its purpose. Petitioners also submitted receipts for the purchase of insecticide, charcoal, and charcoal starter. Based on the record presented, and using our best estimate, we find, and thus hold, that petitioners are entitled to a deduction for job-search expenses in the amount of $8,000 for 1989.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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