Joellen Miller Murata - Page 17

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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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