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section 217 have been satisfied (in the case of all remaining
moving expenses claimed).
With respect to the pre-move househunting expenses claimed,
such expenses are deductible only if incurred after the taxpayer
has obtained employment at the new location. If the new work is
self-employment, the taxpayer is treated for this purpose as
having obtained new employment when substantial arrangements to
commence such work have been made. Sec. 217(b)(1)(C), (f)(2).
For these purposes, the new principal place of work for
petitioner would be Hong Kong. In light of petitioner's
testimony that at the time of his move to Hong Kong he had no
specific plans to begin any particular business, we conclude that
petitioner had not made "substantial arrangements" within the
meaning of section 217(f)(2) at the time of the move, and
consequently he has failed to show his entitlement to a deduction
for any pre-move househunting expenses.
As for petitioner's claimed deduction for expenses of
temporary quarters, the record is devoid of any substantiation of
the actual expenditures for such quarters, or of any evidence
from which the Court could determine the point in time (after
arrival) when substantial arrangements to commence work had been
made so that the expenditures might be eligible for deduction.
Sec. 217(b)(1)(D), (f)(2). Thus, petitioner has failed to show
his entitlement to a deduction for temporary quarters expenses.
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