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expenditures are deductible under section 162(a) regardless of
whether employment is obtained. See Cremona v. Commissioner, 58
T.C. 219 (1972). Deductible job-seeking expenses can include
travel expenses while away from home. See Kozera v.
Commissioner, T.C. Memo. 1986-604. The deduction for expenses
incurred away from home is intended to mitigate the burden of a
taxpayer who, because of the travel requirements of his trade or
business, must maintain two places of abode and therefore must
incur duplicate living expenses. See Barone v. Commissioner, 85
T.C. 462, 466 (1985), affd. without published opinion 807 F.2d
177 (9th Cir. 1986).
In order to be allowed as a deduction under section 162, a
taxpayer must establish that the travel expenses were: (1)
Reasonable and necessary; (2) incurred while away from home; and
(3) incurred in pursuit of a trade or business. See Horton v.
Commissioner, 86 T.C. 589, 593 (1986). Petitioners claimed
substantial amounts attributable to lodging, food, travel,
postage, long-distance telephone calls, and car insurance as job-
hunting expenses. These expenses were incurred during the period
January through July 1995.
Respondent has two alternative theories for denying the job-
hunting expenses. First, respondent contends that petitioner had
no tax home in 1995, and therefore none of the traveling expenses
can be deducted because they were not incurred "while away from
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