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in issue. On their 1997 tax return, petitioners claimed a
deduction for Schedule C business expenses of $17,809, consisting
of advertising expenses, car and truck expenses, office expenses,
taxes and licenses, and travel expenses. Petitioners listed Mr.
Evan’s profession on the Schedule C as a “Licensed Real Estate
Broker & State Certified Appraiser”. Petitioners reported no
income on the Schedule C from any business activities.
On petitioners’ tax return for 1998, Mr. Evan listed his
occupation as “Professor”, and Mrs. Evan listed her occupation as
“Claims Authorizer”. Petitioners claimed a deduction for
Schedule A unreimbursed employee expenses of $31,445, consisting
of parking fees, tolls, transportation, travel expenses, business
expenses, union and professional dues, professional
subscriptions, and job search costs, but reported no wages from
Mr. Evan’s occupation as a professor. Petitioners reported wages
from Mrs. Evan’s employment with the Social Security
Administration. Petitioners also claimed a deduction for
Schedule C business expenses of $6,752, consisting of advertising
expenses, car and truck expenses, depreciation, office expenses,
expenses for supplies, and travel expenses. On the Schedule C,
Mr. Evan listed his principal business as “RE Broker, Appraiser”
but did not report any income from any business activities.
Mr. Evan did not have interviews scheduled for any of the
job-hunting trips for which petitioners claimed expense
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