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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 profit
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