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purchased during the taxable year for which the return was made.
Sec. 1.162-3, Income Tax Regs.
Petitioners presented no documentation to support their
claimed deduction of $3,510 for supplies and equipment. There is
no rational basis in the record on which we can estimate the
magnitude of this expense. We therefore sustain respondent’s
disallowance of this component of the claimed excess unreimbursed
employee and other miscellaneous expenses deduction.
Petitioners deducted $4,800 for job search expenses in
connection with Mrs. Harrell’s efforts to secure employment as
well as deducting $2,850 for “telephone cell phone” expense for
the taxable year in issue. We consider these two expenses
together because they are subject to more stringent substantiation
requirements than the other components of the disallowed employee
expense deduction.
Job search expenses are deductible under section 162(a) to
the extent they are incurred in searching for new employment in
the employee’s same trade or business. See Primuth v.
Commissioner, 54 T.C. 374, 377-378 (1970). However, if the
employee is seeking a job in a new trade or business, the expenses
are not deductible under section 162(a). See Frank v.
Commissioner, 20 T.C. 511, 513-514 (1953). Job search expenses
include r�sum� preparation expenses, postage, and travel and
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