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unreimbursed employee expenses for the 1994 tax year on Form 2106
in the following amounts:
Expenses Amount
Vehicle expenses $4,048
Meal and entertainment expenses 6,422
Travel and lodging expenses 5,680
Total 16,150
Respondent determined that petitioners were not entitled to
deduct unreimbursed employee expenses in the amount of $15,123 as
traveling expenses incurred while away from home because
petitioner's employment with Motorola was for an indefinite term,
and, therefore, respondent disallowed the amount. Petitioners
contend that petitioner's home was in Arlington, Texas, and that
petitioner incurred deductible unreimbursed employee expenses
while petitioner was temporarily working for Motorola in Seguin,
Texas.
Discussion
1. Unreimbursed Employee Expense Deductions
Deductions are a matter of legislative grace. New Colonial
Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Taxpayers bear
the burden of proving that they are entitled to the deductions
they claim. Welch v. Helvering, 290 U.S. 111, 115 (1933).
Section 162(a) allows a taxpayer to deduct all ordinary and
necessary business expenses paid or incurred during the taxable
year in carrying on any trade or business. No deduction is
allowed for personal, living, or family expenses. Sec. 262.
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