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1,311 miles. Petitioner had three job interviews while in Las
Vegas. The first job interview was in Bull Head City, Arizona, a
distance of about 100 miles from the hotel that petitioner was
residing in. The record does not disclose the distances
petitioner traveled for his second and third interviews.
Petitioner was unable to secure a teaching position in the Las
Vegas area. While in Las Vegas, petitioner contacted a high
school principal he knew in El Paso, Texas, who hired petitioner
over the telephone.
Petitioner gambled every day from his arrival in April until
he left Nevada for El Paso, Texas, in late July 1995.
Petitioners claimed $9,764 in job-hunting expenses on their 1995
Federal income tax return. Respondent disallowed the claimed
expenses.
OPINION
Section 162(a)(2) permits a deduction for ordinary and
necessary expenses incurred in carrying on a trade or business,
including traveling expenses (which include amounts expended for
meals and lodging other than amounts that are lavish or
extravagant under the circumstances) while away from home in the
pursuit of a trade or business. In addition to deducting
expenses relating to temporary employment away from home, a
taxpayer may also deduct expenses incurred in seeking employment.
See Primuth v. Commissioner, 54 T.C. 374 (1970). These
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