Robert A. White - Page 15

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               To the extent that an employee incurs expenses searching for           
          new employment in the employee’s same trade or business, the job            
          search expenses are deductible under section 162(a).  See Primuth           
          v. Commissioner, 54 T.C. at 377-378.  However, if the employee is           
          seeking a job in a new trade or business, the expenses are not              
          deductible under section 162(a).  See Frank v. Commissioner, 20             
          T.C. 511, 513-514 (1953).  Job search expenses include resume               
          preparation expenses, postage, and travel and transportation                
          expenses.  See Murata v. Commissioner, T.C. Memo. 1996-321.                 
               Petitioner did not provide any documentary evidence that he            
          actually incurred any job search or resume expenses in 2003.  We            
          do not accept petitioner’s testimony as a reasonable basis to               
          estimate any job search or resume expenses.  Respondent’s                   
          determination as to the claimed job search and resume expense               
          deductions is sustained.                                                    
               Business Cards and Briefcase                                           
               Petitioner claimed deductions of $105 for business cards and           
          $210 for a briefcase.  Petitioner did not provide any receipts to           
          document that he purchased these items in 2003.                             
               Petitioner introduced a business card that identifies him as           
          an immigration inspector for the INS within the Department of               
          Justice.8  Petitioner testified that “We weren’t allowed business           

               8 Petitioner began working for the INS in 1997 and did not             
          specify when he purchased these business cards.  These cards were           

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