Emmanuel I. Nwachukwu - Page 4




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          Equalization, petitioner went to Nigeria for 1 month, during                
          which time he visited relatives and attended one job interview              
          arranged by his cousin.  Because petitioner did not take any                
          business attire with him to Nigeria, after his arrival,                     
          petitioner bought a new suit, shirt, and shoes for the interview.           
          Petitioner deducted the cost of the trip to Nigeria, including              
          the cost of the new clothes, as a job-search expense.  Petitioner           
          also deducted the costs of trips to Los Angeles and Texas as job-           
          search expenses.  Petitioner was not able to find another job,              
          and he collected unemployment insurance for the remaining portion           
          of 1995.                                                                    
                                       OPINION                                        
               Respondent determined that petitioner was not entitled to              
          the deductions he claimed on his return because petitioner did              
          not provide any substantiation for the amounts reported.                    
          Petitioner has no receipts, canceled checks, or other records to            
          substantiate his claimed deductions; however, he did proffer a              
          reconstruction of the expenses, which he prepared for trial, that           
          he asserts supports his claims.                                             
               We begin by noting that, as a general rule, respondent's               
          determinations are presumed correct, and petitioner bears the               
          burden of proving otherwise.  See Rule 142(a); Welch v.                     










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