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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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