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record, we find that the delegation fee also covered lodging and
travel within China. Neither the meals, lodging, or travel
expenses covered by the delegation fee have been separately
accounted for, as required by section 1.274-5T(b)(2)(i),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
Thus, these amounts are not deductible. While we also believe
that some portion of the delegation fee likely represented a fee
for attending the conference, there is no evidence in the record
from which we might discern that portion, as distinguished from
amounts subject to section 274(d)'s limitations. Accordingly,
the entire fee is disallowed under section 274(d).
Petitioner claimed a deduction for job-hunting expenses in
the amount of $2,372.96. Respondent argues that the trips were
primarily personal in nature. Petitioner took five trips during
the year in issue during which she interviewed for positions in
the health field. On all the trips, she stayed with colleagues
or friends. The first trip was to San Francisco. She had a 1-
day interview and stayed in San Francisco from March 14 through
March 17. The second trip was to Beckley, West Virginia.
Petitioner had a 1-day interview and stayed in Beckley from
July 1 to July 6. Petitioner has family in West Virginia. The
third trip was to Los Angeles, California. Petitioner again had
a 1-day interview and stayed in Los Angeles from July 6 to July
11. The fourth trip was to Los Angeles, beginning November 27.
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