John Allen and Glenna A. Lyle - Page 12




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          expenses from Nashville to Las Vegas.  Petitioner drove a total             
          of 200 miles to his job interview in Bull Head City, Arizona, and           
          is entitled to a travel deduction of $60 as a job-hunting expense           
          (200 miles times 30 cents per mile).  See Rev. Proc. 94-73, 1994-           
          2 C.B. 816.                                                                 
          IV.  Temporary Living Expenses                                              
                                  FINDINGS OF FACT                                    
               After accepting a teaching position in El Paso, Texas, over            
          the telephone, petitioner left Las Vegas in late July 1995.                 
          Petitioner's job commenced on August 1, 1995.  As of September 8,           
          1997, 2 years after the job commenced, petitioner continued to              
          reside in El Paso, and his wife continued to reside in Nashville.           
                                       OPINION                                        
               Petitioner asserts that he is entitled to deduct $5,240 in             
          living expenses as "temporary living expenses".  These expenses             
          were incurred during the period from August through December                
          1995.  Petitioner contends that he is entitled to deduct his                
          living expenses during this period because he lived in El Paso              
          for less than 6 months during 1995.  We find petitioner's                   
          argument to be flimsy and farfetched.                                       
               The fact that petitioner lived at a certain address for less           
          than 6 months during the taxable year is not necessarily relevant           
          or important to the question of whether he is entitled to deduct            
          living expenses.  An employee employed temporarily at a distance            





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