Joellen Miller Murata - Page 19

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            have to be resolved in the Rule 155 proceeding.  However, since                            
            the per diem amount includes laundry expenses, she is not                                  
            entitled to an additional deduction for laundry expenses.                                  
                  We now consider the issue of Mr. Ganong's job-search                                 
            expenses.7  Mr Ganong did not testify, and petitioner presented                            
            no detailed testimony or documentation regarding Mr. Ganong's job                          
            search activities.  Moreover, other than the receipt for a plane                           
            ticket, petitioner has presented nothing to substantiate the                               
            amount claimed for Mr. Ganong's job search expenses.  In                                   
            addition, based on petitioner's testimony that Mr. Ganong, a                               
            self-employed artist, was seeking employment in the business end                           
            of the art field, such as a gallery, it appears that Mr. Ganong                            
            was seeking a job in a new trade or business.  Based on the                                
            foregoing reasons, petitioner is not entitled to a deduction for                           
            Mr. Ganong's job search expenses.                                                          
            Not-for-profit Rental                                                                      
                  Petitioner claimed a Schedule A deduction for "not-for-                              
            profit" rental expenses in the amount of $3,417.69.  Petitioner                            
            testified that this amount relates to the mortgage that Mr.                                
            Miller paid during 1991 and for which petitioner included in                               
            income $3,416.92.  Although the facts seem to indicate that                                
            petitioner was an accommodation maker, realizing neither income                            

            7  We note that a portion of the disallowed amount has been                                
            allowed as petitioner's return trip from Los Angeles to                                    
            Rochester.  See supra p. 13.                                                               




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