- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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