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disallowed petitioners' Schedule A deduction for unreimbursed
employee expenses because the expenses claimed were not shown to
be ordinary and necessary nor had petitioners established that
the expenses were not reimbursable by petitioner's employer. In
the notice of deficiency for the tax year 1992, respondent
disallowed petitioners' Schedule A employee business expenses for
lack of substantiation. Respondent also disallowed petitioners'
Schedule C deductions for automobile expense as personal
commuting costs and disallowed Mrs. Tesar's home office expense
because it was not ordinary and necessary. Respondent further
determined an accuracy-related penalty under section 6662(a). In
the notice of deficiency for the tax year 1993, respondent
disallowed petitioners' deduction for employee business expense
due to a lack of substantiation. Respondent further determined
an accuracy-related penalty pursuant to section 6662(a).
As an initial matter, petitioners assert that respondent
audited petitioners' prior years' returns with respect to claimed
deductions for expenses for the purchase of comic books and for
the use of a portion of petitioners' home by Ms. Tesar as her
office, and they contend that respondent allowed those
deductions. Petitioners argue that deductions should therefore
be allowed for amounts paid or incurred for these items during
the years in issue because they are identical in character to
those previously subject to audit. We are not persuaded by
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