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In the present case, petitioner's testimony pertaining to
these objective factors was vague at best. Petitioner testified
concerning his expenditures in Nashville and Las Vegas; however,
his explanations were lacking in meaningful detail. Although
petitioner did not have a principal place of business during much
of 1995, several objective factors indicate that Nashville,
during the period from January through July 1995, was
petitioner's permanent place of residence. First, petitioners
resided in Nashville from August 1994 through March 1995, a
period of 8 months. Second, during the period beginning January
and until August 1995, petitioners paid rent on an apartment in
Nashville, a substantial living expense.
A. Job-Hunting Expenses in Nashville
Since Nashville was petitioner's permanent place of
residence, he was not away from home during his job-searching in
Nashville, and therefore the expenditures for lodging in
Nashville are not deductible. Petitioner drove a total of 210
miles to various job interviews in the Nashville area, and is
entitled to a travel deduction of $63 as a job-hunting expense
(210 miles times 30 cents per mile). See Rev. Proc. 94-73, 1994-
2 C.B. 816. No amount for meals, postage, long-distance
telephone calls or car insurance is allowable because petitioner
has not substantiated that these expenses were related to his
job-hunting.
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