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in the business use of their home. Petitioners claimed a
Schedule A deduction in the amount of $8,681 before the 2-percent
floor for petitioner's unreimbursed employee business expenses.
This deduction includes dues in the amount of $404, automobile
expense in the amount of $671, and vocational supplies in the
amount of $7,606. On their Federal income tax return for 1992,
petitioners claimed a Schedule C deduction for car and truck
expense incurred by Mrs. Tesar in the amount of $3,084, including
depreciation expense in the amount of $2,780. Petitioners also
claimed a Schedule C deduction for home office expense in the
amount of $2,193. Petitioners claimed a Schedule A deduction in
the amount of $9,299 for petitioner's unreimbursed employee
expenses. On their Federal income tax return filed for 1993,
petitioners claimed a Schedule A deduction for petitioner's
unreimbursed employee business expenses in the amount of $14,186,
including vocational supplies in the amount of $12,648, small
tools in the amount of $91, and textbooks in the amount of $54.
In the notice of deficiency for the tax year 1991,
respondent disallowed petitioners' Schedule C deduction for car
and truck expense for lack of substantiation and for failure to
establish any amount expended was ordinary and necessary.
Respondent disallowed petitioners' home office expense deduction
because it was not established that this expense was ordinary and
necessary for Mrs. Tesar's trade or business. Respondent also
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