Rick D. Lamb and Susan L. Story - Page 10

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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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