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not required to accept a taxpayer’s uncorroborated testimony, and
we decline to do so here. See Tokarski v. Commissioner, 87 T.C.
74, 77 (1986). Furthermore, petitioners have failed to show that
they were not entitled to reimbursement from their employers for
the claimed deductions. Therefore, the record does not sustain a
deduction for unreimbursed employment expenses in excess of what
respondent has already allowed.
Investment Expenses
Petitioners claim that they are entitled to investment
expense deductions for their pro rata share of the annual
operating expenses incurred by the mutual funds in which they
owned shares. Petitioners also claim investment expense
deductions for their alleged IRA maintenance, newspaper,
magazine, and letter-writing costs. Section 212 allows a
deduction for all ordinary and necessary expenses paid or
incurred for management, conservation, or maintenance of property
held for the production of income.
The annual operating expenses for the mutual funds are
expenses of the individual funds and are not expenses of
petitioners. Publicly offered mutual funds pass through income
to shareholders on a net basis, i.e., gross income minus
operating expenses. Therefore, petitioners have already received
the benefit of a reduction in income for these costs and are not
allowed to deduct the operating expenses as investment expenses.
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