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before trial, about 6 years after the year in issue, and it was
prepared in contemplation of litigation. Also, petitioners’
testimony supporting such expenses is vague and unclear. Under
the circumstances this log cannot be given any weight by this
Court.
Furthermore, petitioners have failed to account for the
discrepancy between their total expenses in their expense log
($11,073) and their Schedule A claimed “job seeking expenses”
($14,971.38). Although most of the expenses were charged to
personal credit cards, petitioners have not provided any
contemporaneous records or documents to show that they paid such
expenses in the amounts set forth. For example, petitioners have
not shown that they requested copies of airfare ticket vouchers,
hotel bills, car rental agreements, or credit card statements to
substantiate their claimed deductions. Petitioners admitted that
the amounts for “job seeking” expenses on the Schedule A are
estimates, and that they cannot provide the supporting documents
that were used to arrive at the amounts of the expenses shown
thereon.
Petitioners have failed to satisfy the requirements of
section 274(d) with respect to any traveling expense that they
might have incurred in seeking employment. Therefore, we
conclude that petitioners have failed to substantiate the
disallowed claimed deduction. See sec. 6001; sec. 1.6001-1(a),
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Last modified: May 25, 2011