Vashon C. and Beverly C. Jackson - Page 8




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               We hold that petitioners are entitled to additional Schedule           
          A itemized deductions for the foregoing amounts of interest and             
          taxes paid on 2117 Hollins Court under section 163(h)(3) and                
          section 164(a), respectively.  See infra note 5.                            
               The third issue for decision is whether petitioners are                
          entitled to deductions for unreimbursed employee business                   
          expenses.                                                                   
               On Schedules A and Forms 2106 attached to their 1990, 1991,            
          and 1992 returns, petitioners claimed unreimbursed employee                 
          business expenses, before the section 67(a) limitations, as                 
          follows:                                                                    
                                    1990      1991      1992                          
               Vashon C. Jackson   $4,222    $4,889    $5,182                         
               Beverly C. Jackson  1,950     2,795     4,680                          
                                   6,172     7,684     9,862                          
               In the statutory notice of deficiency, respondent disallowed           
          any deductions for the claimed expenses.                                    
               Section 162(a) allows a deduction for the ordinary and                 
          necessary expenses paid or incurred during the taxable year in              
          carrying on a trade or business, including the trade or business            
          of being an employee.  Commissioner v. Flowers, 326 U.S. 465                
          (1946).  If an employee's ordinary and necessary business                   
          expenses exceed the amounts received from his employer as                   
          advances or reimbursements, the employee is entitled to a                   
          deduction for such excess, if adequately substantiated.  See sec.           






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