- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011