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Petitioners’ claimed deduction for job search expenses of
$7,930 consisted of: The cost of transportation to job
interviews, the cost of retaining a search firm to assist with
the search, and the cost of preparing and printing Mr. Stukes’s
calling cards, résumé, and envelopes. Respondent does not
dispute that petitioners would be entitled to deduct these
expenses if they substantiated them adequately, but respondent
maintains that they failed to do so.
As discussed supra, section 274, which imposes strict
substantiation requirements, applies to transportation expenses
involving a “passenger automobile”. In order to establish the
number of miles Mr. Stukes drove pursuant to his job search,
petitioners submitted a log captioned “Job Search Mileage
Expenses/Deductions” (petitioners’ job search mileage log) which
was not prepared contemporaneously with the interviews but rather
was prepared on the basis of contemporaneous calendar records and
bank statements that show costs incurred on specific dates.
It appears from the record that Mr. Stukes was terminated
from his employment in June 2002. We find that petitioners’ job
search mileage log, taken together with the calendar, bank
records, and Mr. Stukes’s credible testimony, substantiates the
transportation expense in search of a job between June and
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