John Allen and Glenna A. Lyle - Page 10

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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               

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