* * *’ Our holding with respect to the precise issue presented herein was foreshadowed by our comments in Eugene A. Carter, 51 T.C. 932, 935 (1969), wherein we said the following with respect to a particular ruling of the respondent to be noted in a moment: However, we think this language was not intended to permit the deduction of a fee where the employment agency merely seeks to locate a position for the taxpayer, as here, but was intended to allow a deduction only where the agency actually obtains a position for the taxpayer.

Expenses for which an employee could claim reimbursement from his or her employer are not necessary business expenses. See Orvis v. Commissioner, 788 F.2d 1406,1408 (9th Cir. 1986) (stating that the prohibition against deductions for reimbursable expenses is a bright line rule and applies even when an employee is unaware that the expenses are reimbursable), aff'g T.C. Memo. 1984-533; see also Carver v. Commissioner, 51 T.C. 932, 936 (1969); Davis v. Commissioner, T.C. Memo. 1999-250. Further, petitioner offered no support for his statement that signing up for the tool reimbursement program converts an employee into a person in a new trade or business with respect to his or her existing tool inventory.

The erroneous past actions of respondent cannot be relied upon to allow a deduction that is not permitted by statute. See Carpenter v. United States, 495 F.2d 175, 184 (5th Cir. 1974); Carter v. Commissioner, 51 T.C. 932, 935 (1969). Moreover, each year is the origin of a new liability and a separate cause of action.

Where the taxpayer pays employment agency fees or incurs other expenses in seeking to move to a new job in a different field of employment, the fees are not deductible. Carter v. Commissioner, 51 T.C. 932, 934 (1969). See also Evans v. Commissioner, T.C. Memo. 1981-413.

Your Federal Income Tax, 1968 ed. for individuals, states at p. 45: ‘If you worked at two places in a day whether or not for the same employer, you may deduct the expense of getting from one such place to the other.’ In the first place, even if Your Federal Income Tax were construed to permit deduction of what would otherwise be nondeductible commuting expenses, it is clear that the sources of authoritative law in the tax field are the statute and regulations, and not informal publications such as Your Federal Income Tax. Dixon v. United States, 381 U.S. 68, 73 (1965); Adler v. Commissioner, 330 F.2d 91, 93 (C.A. 9, 1964); Eugene A. Carter, 51 T.C. 932, 935 (1969). Secondly, petitioner's argument places excessive reliance on the few words he selects from Your Federal Income Tax, and ignores the clear purport of the booklet as a whole.

In this respect, as respondent points out, in the cited cases the taxpayer either obtained a new job as a result of the expenditure in question or was offered a job. Where neither a job nor an opportunity of employment results from the expenditure, the respondent would deny the deduction, citing Eugene A. Carter, 51 T.C. 932 (1969). At the outset, we believe that the Carter case is distinguishable in that the taxpayer in that case was in the military service.