- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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