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13213 apply to expenses incurred after December 31, 1993. OBRA
sec. 13213(e), 107 Stat. 475. Before its amendment by OBRA,
former subparagraphs (D) and (E) of section 217(b)(1) allowed
deductions for expenses of meals and lodging while occupying
temporary quarters and qualified residence sale or purchase
expenses.
Petitioner incurred his moving expenses after December 31,
1993. Accordingly, any expenses for temporary housing, for the
sale of his former residence, and for the purchase of a new
residence are not deductible pursuant to section 217.
Furthermore, section 217 does not allow a deduction for
relocation allowances.
Section 1.217-2(b)(3), Income Tax Regs., provides:
Expenses of moving household goods and personal effects
include expenses of transporting such goods and effects
from the taxpayer’s former residence to his new
residence, and expenses of packing, crating, and in-
transit storage and insurance for such goods and
effects. * * * Expenses of storing and insuring
household goods and personal effects constitute in-
transit expenses if incurred within any consecutive 30-
day period after the day such goods and effects are
moved from the taxpayer’s former residence and prior to
delivery at the taxpayer’s new residence. * * *
Expenses of moving household goods and personal effects
do not include, for example, storage charges (other
than in-transit) * * * .
On May 22, 1998, petitioner sold his house in Northglenn,
Colorado. On May 27, 1998 petitioner purchased a house in Fort
Collins, Colorado. Petitioner, however, presented no evidence
regarding whether the items in storage were moved from his former
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