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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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