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respectively, for cash gifts to charities.
In the notice of deficiency, respondent disallowed:
(1) All of the deductions claimed on the Schedules C; (2) $2,245
of the charitable contribution deduction claimed for 1995; and
(3) the entire charitable contribution deduction claimed for
1996. Among other reasons, the disallowances were based upon
lack of substantiation. Other adjustments made in the notice of
deficiency are not in dispute.
Discussion
A. Schedule C Deductions
For each year, petitioners claimed numerous deductions on a
Schedule C. All of the deductions were disallowed in the notice
of deficiency. Petitioners claim that they are entitled to the
deductions because the underlying expenses were incurred by
petitioner in carrying on a trade or business as a self-employed
professional engineer. See sec. 162(a). We disagree.
Petitioner did not earn any income or provide any services
as an engineer during either year in issue. The expenses
deducted on the Schedules C relate primarily to his attempts to
find employment. As we view the matter, the expenses that
underlie the Schedule C deductions are properly characterized as
job hunting expenses. During temporary periods of unemployment,
job hunting expenses can be considered and deducted as trade or
business expenses if the expenses are incurred during “a
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