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stayed in the home she owned in the Los Angeles area, that her
son lived in the home, and that her visit occurred during the
holiday season. These facts, together with the fact that the
time spent on job search activities was minimal, lead us to
conclude that the primary purpose of the trip was personal and
that the portion of the expenses that could be allocated to any
job search activities would be minimal at best. Accordingly,
petitioner is not entitled to a deduction for expenses associated
with that trip.
With regard to the second trip to Los Angeles from December
18, 1991, through December 31, 1991, petitioner presented a daily
calendar for 1991, which indicates that she interviewed at Kaiser
Research Group and CSUN. In addition, petitioner made telephone
calls related to resumes which she had sent to prospective
employers in the area. Although the matter is not free from
doubt, due to some of the same circumstances being present as in
the first trip, we conclude that the primary purpose for the
second trip was for business purposes and that petitioner is
entitled to a deduction for job search expenses related to this
trip.
Petitioner presented an airline receipt for $481 from
American Airlines and testified that she incurred shuttle
expenses of $8. Accordingly, we shall allow petitioner a
deduction for job search expenses of $489.
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