George A. and Christine M. Evan - Page 12

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          available to an employee of the university, not that Mr. Evan is            
          an employee.  Further, the parties stipulated that:  (1) Mr.                
          Evan’s employment with Purdue University expired on June 30,                
          1992; (2) Mr. Evan did not teach any courses or provide any other           
          services to Purdue University or any affiliate of Purdue                    
          University from January 31, 1992, through the years in issue; and           
          (3) Mr. Evan received long-term disability benefits from the                
          university from June 18, 1992, through the years in issue.  As a            
          result, we conclude that Mr. Evan was not an employee of Purdue             
          University during the years in issue, and, therefore, petitioners           
          are not entitled to a deduction for expenses claimed to have been           
          incurred in such employment.                                                
               C.   Job-Hunting and Education Expenses                                
               Petitioners argue that respondent erred in disallowing the             
          job-hunting and education expenses reported because they were               
          connected with Mr. Evan’s trade or business of being a professor.           
          We disagree.                                                                
               The deductible expenses allowable under section 162(a)                 
          include those incurred in searching for new employment in the               
          employee’s same trade or business.  Cremona v. Commissioner, 58             
          T.C. 219, 222 (1972); Primuth v. Commissioner, 54 T.C. 374, 379             
          (1970).  If the employee is seeking a job in a new trade or                 
          business, however, the expenses are not deductible under section            
          162(a).  Frank v. Commissioner, 20 T.C. 511, 513 (1953); Hobdy v.           






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