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business is earning his compensation, and generally only those
expenses that are related to the continuation of his employment
are deductible. Noland v. Commissioner, 269 F.2d 108, 111 (4th
Cir. 1959), affg. T.C. Memo. 1958-60. Pursuant to section
162(a), if expenditures qualify as "ordinary and necessary", an
employee may deduct unreimbursed employee expenses. An employee
may not deduct such expenses, however, if the expenses are not
substantiated or if the employee has a right to, but fails to
seek, reimbursement from the employer. Kennelly v. Commissioner,
56 T.C. 936, 943 (1971), affd. without published opinion 456 F.2d
1335 (2d Cir. 1972). Paula testified that her employer would have
reimbursed her for the garment shields for school costumes had
she sought a reimbursement. We, therefore, sustain respondent's
determination with respect to this deduction.
Petitioners claimed deductions for concert tickets which
Paula attended with her husband or students. For expenses to be
deductible under section 162, petitioners must show that the
purpose of the expenditure was primarily business rather than
personal and that Paula's business benefited, or was intended to
benefit, by the expenditure. Hynes v. Commissioner, 74 T.C.
1266, 1289 (1980); Schulz v. Commissioner, 16 T.C. 401, 405
(1951). Paula claims that she attended concerts to learn about
the changes in jazz dance for her business as a dance instructor.
We conclude that petitioners have failed to demonstrate that the
purpose of the concerts was primarily business rather than
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