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transaction which gives rise to the expense must be of a common
or frequent occurrence in the type of business involved. Deputy
v. du Pont, 308 U.S. 488, 495 (1940). To be “necessary” an
expense must be “appropriate and helpful” to the taxpayer’s
business. Welch v. Helvering, 290 U.S. 111, 113-114 (1933). The
performance of services as an employee constitutes a trade or
business. See sec. 1.162-17(a), Income Tax Regs. The employee
must show the relationship between the expenditures and the
employment. See Evans v. Commissioner, T.C. Memo. 1974-267.
Such deductible expenses include those incurred in searching
for new employment in the employee’s same trade or business.
Cremona v. Commissioner, 58 T.C. 219 (1972); Primuth v.
Commissioner, 54 T.C. 374 (1970). It does not matter whether the
search is successful, or even whether the taxpayer accepts a new
position when it is obtained. See Cremona v. Commissioner, supra
at 221-222; Kenfield v. Commissioner, 54 T.C. 1197, 1199-1200
(1970). It does not matter that the taxpayer is temporarily
unemployed while searching, or that the taxpayer is temporarily
engaged in a different trade or business while searching for a
new position in the trade or business previously conducted by the
taxpayer. See Primuth v. Commissioner, supra at 378; Charlton v.
Commissioner, T.C. Memo. 1988-515. Job search expenses include
resum� preparation expenses, postage, and travel and
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