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ascertain their needs regarding recruitment, possibly in
connection with an immigration visa service he contemplated
providing, and (2) his contacting a bank to ascertain its
interest in establishing a money wire transfer service to
Nigeria. We find this brief testimony to be insufficient to
establish the existence of any continuous and regular activity
which constituted a trade or business. See sec. 162(a);
Groetzinger v. Commissioner, supra.
On petitioner’s returns, he indicated that a portion of the
employee business expenses was job search expenses. The nature
of the expenses discussed above, however, does not give rise to
job search expense deductions because petitioner was not
searching for a job within the same trade or business. See Frank
v. Commissioner, supra.
We uphold respondent’s disallowance of petitioner’s claimed
itemized deductions for employee business expenses.
The final issue for decision is whether petitioner is liable
for the accuracy-related penalty under section 6662(a) for
negligence or disregard of rules or regulations for each of the
years in issue. Respondent determined that petitioner was liable
for the penalty for an underpayment equal to the total amount of
the deficiency in each year in issue.
Section 6662(a) imposes a 20-percent penalty on the portion
of an underpayment attributable to any one of various factors,
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