- 4 - Alexander v. Commissioner, T.C. Memo. 1995-51, affd. 72 F.3d 938 (1st Cir. 1995). Petitioners' argument consists of policy arguments that are not supported by the statutes or by case law (none is cited by petitioners). Petitioners feel that they should be entitled to deduct unreimbursed employee expenses on their Schedule C and “request that the Tax Court recommend to Internal Revenue that this situation be corrected either by the reinstatement of the pre-1984 method of subtracting all trade deductions or by inclusion of the 'Statutory Employee' designation for those employees who are delivering or constructing on site.” Petitioners have chosen the wrong forum in which to raise these arguments. If petitioners would prefer the law to be different, we would refer them to Congress. See U.S. Const. art. 1, sec. 1. Petitioners bear the burden of proof. Rule 142(a). They have shown no reason why they fall outside the reach of section 67. Accordingly, we sustain respondent's determination. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4
Last modified: May 25, 2011