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reasonable period of transition” between leaving one position and
obtaining another. Haft v. Commissioner, 40 T.C. 2, 6 (1963);
see also Sherman v. Commissioner, T.C. Memo. 1977-301.
In this case, petitioner retired as an engineer from the
USAF in 1989. He apparently was employed in some capacity as an
engineer for an undisclosed period in 1991, and he remained
unemployed from then throughout the years in issue until January
1999, when he was again employed as an engineer by the USAF, this
time as a civilian. As of the beginning of 1995, petitioner had
been unemployed for at least 3 years. We think that the
“reasonable period of transition” that began at the conclusion of
petitioner’s 1991 job expired sometime before the beginning of
1995. Consequently, as of the beginning of 1995, petitioner
would no longer be considered to be carrying on a trade or
business within the meaning of section 162(a).
Moreover, even if we were to find that petitioner was
engaged in a trade or business during the years in issue, other
grounds exist for disallowing particular deductions. For
example, because petitioners reported no gross income from that
trade or business, no deductions attributable to the office in
petitioners’ home would be allowable. See sec. 280A. The
deductions claimed for travel and meals expenses relate primarily
to several trips each year to Birmingham, Alabama, Williamsburg,
Kentucky, and Columbia, Missouri. According to petitioner, those
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