John Allen and Glenna A. Lyle - Page 11

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               B.  Job-Hunting Expenses in Las Vegas                                  
               Petitioner also claimed significant travel expenses for the            
          period beginning April through July 1995.  Since we have                    
          determined that petitioner's tax home was Nashville, the expenses           
          must be allocated between petitioner's gambling and job-hunting             
          activities.  It is difficult to discern the amount of time                  
          petitioner spent on his gambling versus his job-hunting                     
          activities.  Considering all of the facts and circumstances, we             
          conclude petitioner spent approximately one-quarter of his time             
          job-hunting in Las Vegas.  Accordingly, petitioner is entitled to           
          a $700 deduction for food and lodging.  No amount for postage,              
          long-distance telephone calls, or car insurance is allowable                
          because petitioner has not substantiated that these expenses were           
          related to his job-hunting.                                                 
               If an employee travels to an area to seek new employment and           
          also engages in personal activities, traveling expenses are                 
          deductible only if the trip is related primarily to seeking new             
          employment.  See sec. 1.162-2(b), Income Tax Regs.  The amount of           
          time during the period of the trip that is spent on personal                
          activity compared to the amount of time spent on seeking new                
          employment is important in determining whether the trip is                  
          primarily personal.  See id.  Petitioner spent most of his time             
          in Las Vegas gambling, rather than seeking new employment.                  
          Accordingly, petitioner is not entitled to deduct his travel                

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