Mark W. and Anita P. Franklin - Page 5

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               The second trip occurred from January 18 to 22, 1998, when             
          petitioners traveled from San Francisco, California, to Los                 
          Angeles, California, again in search of employment for both of              
          them.  Petitioner was seeking employment with his current                   
          employer or another airline company in Los Angeles, while                   
          petitioner wife conducted a “cold canvas search” with various               
          employers in Los Angeles, Long Beach, Santa Ana, Pasadena,                  
          Anaheim, Riverside, Irvine, and Burbank, California.  The total             
          expense of this employment search was allegedly $1,592.  Of this            
          amount petitioners calculated $515 for hotel expenses; $287 for             
          meal expenses; $234 for car rental expenses; $100 for gas                   
          expenses; $430 for air fare expenses; and $56 for parking                   
          expenses.                                                                   
               The third trip occurred from February 1 to 5, 1998, when               
          petitioners traveled from San Francisco, California, to                     
          Washington, D.C., in search of employment for both of them.                 
          Petitioner was seeking employment with his current employer or              
          another airline company in Washington, D.C., while petitioner               
          wife conducted a “cold canvas search” with various employers in             
          Washington, D.C.; Fairfax, Vienna, Reston, Arlington, and McLean,           
          Virginia; and Silver Spring, Oxon Hill, Adelphi, and Bethesda,              
          Maryland.  The total expense of this employment search was                  
          allegedly $2,927.  Of this amount petitioners calculated $569 for           
          hotel expenses; $418 for meal expenses; $253 for car rental                 






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