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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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