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deductions were for essentially personal expenses that did not
constitute trade or business expenses. Some of the claimed
deductions were for job search expenses, which respondent
disallowed. To the extent any of the Schedule C deductions were
allowed, they were allowed as miscellaneous itemized deductions
on Schedule A of the returns.
Petitioners contend that the disallowed Schedule C
deductions were all for job search expenses. In auditing
petitioners’ returns for the 2 years at issue, respondent
determined that the expenses deducted for the 2 years at issue
were essentially and primarily personal expenses. For example,
the Schedule C for 1999 included expenses incurred by petitioners
in the use of their motor home beginning in January through mid-
April to various places in the West and Southwest. Petitioners
contend these were job search expenses. Petitioner did have
between 15 and 20 interviews with doctors and at hospitals,
although no offers of employment were ever made. Petitioner’s
journey in quest of a job included San Diego, California,
Arizona, Nevada, and the Oregon coast. The trip, however,
included visits to vineyards and wine tasting in California, Sea
World at San Diego, the Grand Canyon in Arizona, other tourist
attractions, and a sister at Scappore, Oregon. During the year
2000, petitioners took another extended excursion in their motor
home to New England, including Burlington, Vermont; Niagra Falls,
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