Veronica Chu - Page 8

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          that State income taxes are allowed as a deduction for the                  
          taxable year within which they are paid or accrued.  Respondent             
          conceded that petitioner was entitled to a $14,513 State income             
          tax deduction.  Petitioner did not produce any evidence at trial            
          to substantiate the additional claimed $1,236 State income tax              
          deduction.  Therefore, petitioner cannot deduct the additional              
          $1,236.                                                                     
                    2.   Unreimbursed Employee Expenses                               
               Petitioner claimed a $3,376 deduction for unreimbursed                 
          employee business expenses incurred during 2000.  Pursuant to               
          section 162(a), a taxpayer may deduct all of the ordinary and               
          necessary expenses paid or incurred during the taxable year in              
          carrying on a trade or business including a trade or business as            
          an employee.  Lucas v. Commissioner, 79 T.C. 1, 6 (1982).                   
          Petitioner did not produce any evidence at trial to substantiate            
          the claimed unreimbursed employee business expenses.                        
          Accordingly, we sustain respondent’s determination regarding the            
          unreimbursed employee business expenses.                                    
               Petitioner attached to her posttrial brief documents to                
          support her claimed deduction for unreimbursed employee expenses.           
          Evidence must be submitted at trial; documents attached to briefs           
          and statements made therein do not constitute evidence and will             
          not be considered by the Court.  Rule 143(b); Evans v.                      
          Commissioner, 48 T.C. 704, 709 (1967), affd. per curiam 413 F.2d            






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