This section contains the nature of the case and procedural background.

Frank (P) took a trip to investigate the possibility of acquiring a newspaper or radio station. P took his wife and went from Pittsburgh as far as San Diego. On the way, they interviewed people. Eventually, they took employment with the Arizona Times and remained in that city for the first half of 1946. While working in Phoenix, they made several trips to locate a purchase candidate. They traveled all over the U.S. in this pursuit. Offers of purchase were made to several owners. Estimated travel expenses incurred were almost $5,925. They took these expenses as a deduction, but none were claimed to be incurred in connection with their employment with the Arizona Times. Eventually, by November 1946 the bought a newspaper in Canton, Ohio. The IRS did not like this deduction and disallowed it. P filed with the tax court.

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