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care expenses were incurred while petitioner was not employed.
See Collins v. Commissioner, T.C. Memo. 1997-129.
Accordingly, we find that petitioner expended $1,500 for
child care during 1995. See Cohan v. Commissioner, supra. The
amount of the section 21 credit allowable for this expense must
be determined by the parties in their Rule 155 calculations.
Issue 4. Job-Search Expenses
Petitioner claimed a Schedule A deduction for job-search
expenses of $5,570. Petitioner testified that he searched in
Nigeria, Los Angeles, and Texas for a job in either banking or
accounting.
Section 162(a) allows a deduction for all the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on any trade or business. Such deductible expenses
include those incurred in searching for new employment in the
employee's same trade or business. See Cremona v. Commissioner,
58 T.C. 219 (1972); Primuth v. Commissioner, 54 T.C. 374 (1970).
Petitioner bears the burden of proving that the expenses were of
a business nature rather than personal and that the expenses were
ordinary and necessary. See Rule 142(a); Welch v. Helvering,
supra.
With respect to petitioner's 1-month trip to Nigeria,
petitioner did not present any documentation or detailed
testimony concerning the specific job-search activities in which
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