Rick D. Lamb and Susan L. Story - Page 13

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          in fact seeking a job, it was not in connection with his claimed            
          self-employment activity.  All of the interviews petitioner had             
          related to the practice of medicine, as an employee.  Therefore,            
          to the extent petitioner incurred any job search expenses, those            
          expenses would not be a Schedule C trade or business expense.               
          The expense would be an employee business expense that would be             
          claimed on Schedule A of the tax return.                                    
               Section 162(a) allows a deduction for ordinary and necessary           
          business expenses.  It is recognized that such deductible                   
          expenses include those incurred searching for new employment in             
          the employee’s same trade or business.  Cremona v. Commissioner,            
          58 T.C. 219 (1972); Primuth v. Commissioner, 54 T.C. 374 (1970).            
          The evidence in this case shows that petitioner was interviewed             
          on several occasions for employment as a medical doctor (and not            
          as an unpaid consultant/adviser).  As also noted and described,             
          petitioner’s job search consisted of two extended trips he and              
          his wife took, by mobile home, during 1999 and 2000, which                  
          included essentially the east and west coasts of the United                 
          States.  On each of these trips, petitioners visited members of             
          their families and numerous tourist attractions.  The job                   
          interviews petitioner had were, in the Court’s view, incidental             
          to the main purpose of the trips--to visit family and tourist               
          attractions.  Petitioners essentially took a vacation and claimed           
          the expenses as tax deductions.  The regulations provide that               






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