Russell B. Ritchie - Page 10

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               Petitioner offered no evidence bearing on whether the new              
          employment he sought was in the same trade or business as his               
          employment at Stores.  Petitioner, in fact, offered no evidence             
          at all on the nature of the new employment he sought.  The                  
          evidence he did offer consisted of 2002 hotel receipts from the             
          Phoenix Hotel in Phoenix, Arizona, a hotel in Redding,                      
          California, and the Hotel Del Coronado.  Petitioner offered no              
          specific testimony or corroborating documentary evidence linking            
          the receipts with job-seeking activity.  The printed information            
          at the top of the receipt from the Hotel Del Coronado states that           
          the room was for petitioner in connection with the “Hudson/Kline            
          Wedding”; his arrival was on New Year’s Eve, and his departure              
          was on New Year’s Day.                                                      
               The Court finds that petitioner is not entitled to any                 
          deduction for job-seeking expenses.                                         
          Charitable Contributions                                                    
               Petitioner indicated on his Schedule A that he made gifts              
          to charity of $1,755, of which $1,260 was by cash or check.                 
          There were upon his own admission, however, no gifts of cash or             
          checks made by petitioner during 2002.  Petitioner did submit as            
          evidence on this issue a copy of a receipt from the United Cancer           
          Research Society for the donation of five items of personal                 
          property.  The receipt announces that the donor is responsible              
          for estimating the fair market value of the items donated.                  






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