John Allen and Glenna A. Lyle - Page 7

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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               
               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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