- 9 - 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 byPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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