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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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