- 17 - 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.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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