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deduct the claimed Schedule C expenses. On that record, we
sustain respondent’s determination to disallow the Schedule C
deductions claimed in the 1995 return.
We shall now consider whether petitioner is entitled to
deduct any of the claimed Schedule C expenses as itemized deduc-
tions subject to the 2-percent adjustment required by section
67(a). If a taxpayer’s trade or business is that of being an
employee, the ordinary and necessary expenses of being an em-
ployee will be treated as itemized deductions, see sec. 62(a)(1),
subject to the limitation of section 67(a), i.e., the 2-percent
adjustment. See Alexander v. IRS, 72 F.3d 938, 944-946 (1st Cir.
1995), affg. Alexander v. Commissioner, T.C. Memo. 1995-51.
Respondent concedes that, of the total Schedule C expenses
claimed by petitioner, expenses aggregating $2,577 qualify as
employee business expenses that constitute miscellaneous itemized
deductions subject to the 2-percent adjustment. Based on our
examination of the entire record before us, we find that peti-
tioner has failed to prove that any additional amount of the
claimed Schedule C expenses qualifies as such an itemized deduc-
tion.
With respect to petitioner’s contention that respondent
erred in determining to disallow certain of the expenditures that
he claimed in the job-expense section of Schedule A, respondent
concedes that petitioner is entitled to $953 of those disallowed
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