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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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