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expenses in the general location of the new job. H. Conf. Rept.
103-213, at 592 (1993), 1993-3 C.B. 393, 470. The term “moving
expenses” means only the reasonable expenses of moving household
goods and personal effects from the former residence to the new
residence and of traveling (including lodging) from the former
residence to the new place of residence. Sec. 217(b)(1).
To qualify for the deduction, the taxpayer must satisfy the
conditions regarding both distance to the taxpayer’s new
principal place of work as set forth in section 217(c)(1) and
duration of full-time employment as set forth in section
217(c)(2). The condition of section 217(c)(2) shall not apply
“if the taxpayer is unable to satisfy such condition by reason of
* * * involuntary separation (other than for willful misconduct)
from the service of, or transfer for the benefit of, an employer
after obtaining full-time employment in which the taxpayer could
reasonably have been expected to satisfy such condition.” Sec.
217(d)(1)(B).
If claimed deductions are not adequately substantiated, we
may estimate them, provided we are convinced that the taxpayer
incurred such expenses and we have a basis upon which to make an
estimate. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930);
Vanicek v. Commissioner, 85 T.C. 731, 743 (1985). Without such a
basis, any allowance would amount to unguided largesse. Williams
v. United States, 245 F.2d 559, 560 (5th Cir. 1957).
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