James E. Harrell - Page 6




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          proceeds from the sale on April 6, 1995.  A deduction for                   
          qualified residence interest paid on indebtedness during the year           
          is allowed under section 163(a) and (h).  In this case,                     
          petitioner did not pay the interest on his home during 1994, the            
          year in issue.  He paid it in 1995 when his house was sold.                 
          Accordingly, we sustain respondent's disallowance of the interest           
          expense deduction.                                                          
               Petitioner claimed $650 of charitable contributions                    
          deductions.  An itemized deduction is generally allowable for               
          charitable contributions made during a year but only if the                 
          contribution is verified in accordance with regulations                     
          prescribed by the Secretary of the Treasury.  Sec. 170(a).  Based           
          on petitioner’s testimony, we allow petitioner a $100 deduction             
          for charitable contributions.  Cohan v. Commissioner, supra.                
               Petitioner deducted $2,300 of unreimbursed employee business           
          expenses for union dues and job-hunting expenses.  Respondent               
          conceded $382.68 for union dues.  Expenses incurred in looking              
          for a new job in a taxpayer's current trade or business are                 
          allowed as an itemized deduction.  Sec. 162(a); Primuth v.                  
          Commissioner, 54 T.C. 374 (1970).  However, if part of the                  
          purpose of a job hunting trip is personal in nature, the personal           
          portion of the expenses is not deductible.  Sec. 262.  Petitioner           
          stated that he looked for jobs in Jackson and Gulfport,                     
          Mississippi, and that the expenses he claimed were for mileage.             





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