- 10 - New York; New Hampshire; Massachusetts; and Connecticut. These trips included visits to Bozeman, Montana, where petitioner’s son lived, to Missoula, Montana, where petitioner’s daughter lived, and to Park City, Montana, where Mrs. Story’s three children lived. Petitioners also visited other relatives in Virginia Beach, Virginia. Despite the obvious personal nature of these excursions, petitioner contends, nonetheless, that these trips were principally in search of a job. All expenses relating to these trips were deducted as Schedule C trade or business expenses for the 2 years in question. Respondent’s position is that, because petitioner realized no income from his claimed activity for the 2 years at issue, he was not engaged in a trade or business; therefore, none of the Schedule C expenses are deductible as trade or business expense, and, to the extent that any of the claimed expenses were deductible, an appropriate allowance was made for such expenses as itemized deductions. The Court further notes that none of the job search expenses claimed related to a relocation of petitioner’s claimed self-employment medical/legal consultation activity. All of the job searching endeavors were directed to petitioner’s employee status as a medical doctor. The Court agrees with respondent’s argument. The law is well settled that a business is a course of activities engaged in for profit. Activities that are for a purpose other than profitPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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