- 15 - 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 disallowedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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