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After concessions by the parties,1 the issues for decision
are: (1) Whether pursuant to section 162, petitioners may deduct
Schedule A job-related education expenses in excess of the
amounts allowed by respondent for the taxable years 1991 and
1992.2 We hold they may, to the extent set out below. (2)
Whether pursuant to section 162, petitioners may claim Schedule A
miscellaneous itemized deductions for the taxable years 1991 and
1992. We hold they may, to the extent set out below. (3) Whether
pursuant to section 162, petitioners may deduct Schedule C
business expenses in excess of the amounts allowed by respondent
for the taxable years 1991 and 1992. We hold they may, to the
1 For 1991, respondent concedes that petitioners are allowed a
Schedule A deduction of $1,536 for the cost of unreimbursed job-
related education courses taken by Mrs. Whalley. Respondent
concedes that petitioners are allowed a Schedule C deduction of
$200 for advertising expenses, $118 for supplies, $125 paid to
the California Association of Licensed Investigators, and $100
for the renewal of petitioner's private investigator's license.
Respondent concedes that petitioner is not required to include in
gross income $97 as a dividend. Petitioner concedes that he
erroneously claimed a $216 bad debt deduction and a deduction for
a $14 parking citation.
For 1992, respondent concedes that petitioners are allowed a
Schedule A deduction of $729 for the cost of unreimbursed job-
related education courses taken by Mrs. Whalley and $240 for tax
preparation fees. Respondent concedes that petitioners are
allowed a Schedule C deduction of $218 for advertising expenses,
$125 paid to the California Association of Licensed
Investigators, and two separate $20 payments made to the Northern
California Fraud Investigators Association. Petitioner concedes
that he erroneously claimed a $150 bad debt deduction.
2 All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated. All dollar amounts are rounded to the nearest dollar.
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