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his own employment. We find that as an officer and director of
Stone Jessup petitioner established the requisite corporate
policy that would allow him, as an employee of the corporation,
to deduct any unreimbursed employee business expenses he incurred
in connection with his employment. See Theodore Souris, P.C. v.
Commissioner, T.C. Memo. 1996-450. We therefore find that as a
condition of petitioner's employment with Stone Jessup he was
required personally to pay expenses that he incurred in
connection with such employment. We further find that petitioner
was only entitled to reimbursement from Stone Jessup for such
expenses if Stone Jessup was financially able to do so, which
during the year in issue, was not the case. Accordingly, we hold
that petitioners are entitled to a deduction for the employee
business expenses specifically listed above in this section of
the opinion.
Credit Life Insurance Premiums
Pursuant to the previously discussed line of credit with the
bank, petitioner obtained several credit life insurance policies,
each naming the bank as beneficiary, and paid $1,142.88 in
premiums. The manner in which petitioners deducted the expenses
for the premiums on their 1991 return, partly on a Form 2106 and
partly as a miscellaneous itemized deduction, leads us to
conclude that they rely upon section 162(a), section 212(2), or
both, in support of the deductions. However, we need not
consider whether the deductions should be allowed under either of
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