Agnes T. Bosco - Page 7

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          make up the $4,100 portion of the $12,449 claimed on her return             
          as a moving expense deduction.  Therefore, respondent is                    
          sustained on that portion of the adjustment in the notice of                
          deficiency.                                                                 
               The remaining portion of petitioner’s claimed moving expense           
          deduction was $8,349 for lodging expenses, which was, as noted              
          before, disallowed by respondent.  The evidence at trial shows              
          that $8,241.24 of the amount claimed was for 3 months of                    
          temporary lodging at an Embassy Suites hotel.  The Form W-2                 
          issued to petitioner included $8,241.24 for temporary lodging               
          expenses paid to the Embassy Suites by Authentic Fitness.                   
          Respondent disallowed that amount as a qualified moving expense.            
          The cost of temporary lodging does not qualify as a moving                  
          expense under section 217(b).  Section 217(b)(1) provides:                  

                    (1) * * * for purposes of this section, the term                  
               “moving expenses” means only the reasonable expenses–                  
                    (A) of moving household goods and personal effects                
                    from the former residence to the new residence, and               
                    (B) of traveling (including lodging) from the                     
                    former residence to the new place of residence.                   
               Such term shall not include any expenses for meals.                    
               [Emphasis added.]                                                      

          Petitioner’s stay at the Embassy Suites did not constitute                  
          lodging while traveling “from the former residence to the new               
          place of residence.”  Sec. 217(b)(1)(B).  Petitioner resided at             






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