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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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