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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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