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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.
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