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airfare, transportation to and from the airport, a per diem meals
allowance, the cost of newspapers, laundry expenses, and
miscellaneous expenses.
Section 162(a) allows a deduction for ordinary and necessary
business expenses. Such deductible expenses include those
incurred in searching for new employment in the employee's same
trade or business. Cremona v. Commissioner, 58 T.C. 219 (1972);
Primuth v. Commissioner, 54 T.C. 374 (1970). If the employee is
seeking a job in a new trade or business, however, the expenses
are not deductible under section 162(a). Frank v. Commissioner,
20 T.C. 511, 513 (1953); Hobdy v. Commissioner, T.C. Memo. 1985-
414; Evans v. Commissioner, T.C. Memo. 1981-413. Petitioner
bears the burden of proving that the expenses were of a business
nature rather than personal and that said expenses were ordinary
and necessary. Rule 142(a); Welch v. Helvering, 290 T.C. at 115.
With regard to the trip to Los Angeles from December 15,
1990, through January 7, 1991, petitioner did not present any
documentation or detailed testimony concerning the specific job
search activities in which she engaged during her trip, other
than making telephone calls and mailing resumes. Moreover, the
record contains no information regarding the amount of time she
devoted to such activity. Although we believe petitioner engaged
in some job search activities, there were personal reasons for
her to be in Los Angeles. We think it significant that she
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