Emmanuel I. Nwachukwu - Page 13




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          he engaged during his trip.  Although we believe that petitioner            
          did engage in some job-search activities, there were personal               
          reasons for him to be in Nigeria.  The record shows that, except            
          for one interview and the delivery of one resume, petitioner                
          spent the month visiting his cousin.  Furthermore, the fact that            
          petitioner went to Nigeria without the business attire he                   
          required for a job interview and without first speaking                     
          personally with the prospective employer, leads us to believe               
          that the purpose of the trip was not to search for a job.  These            
          facts, together with the fact that the time spent on job-search             
          activities was minimal, support a conclusion that the portion of            
          the expenses that could be allocated to any job-search activities           
          would be minimal at best.  Accordingly, petitioner is not                   
          entitled to a deduction for expenses associated with this trip.             
               With respect to petitioner's claims for the expenses of the            
          job searches in Los Angeles and Texas, petitioner did not have              
          any records, receipts, canceled checks, or any other                        
          documentation to substantiate the expenditures.  Nor could he               
          remember whether certain amounts he listed in his reconstruction            
          were expended during his trip to Los Angeles or during his trip             
          to Texas.  Moreover, petitioner was unable to provide any details           
          of where he stayed or the name of the firms with which he                   
          interviewed.  Finally, petitioner claimed he expended $2,346 on             
          miscellaneous items related to his job search; however, he could            






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