- 9 - training, to ensure that the new pilots were proficient with its aircraft, and to ensure the safety of its passengers. The evidence in the record clearly establishes that petitioner incurred unreimbursed expenses as a requirement of his employment as a pilot with CE. The expense petitioner incurred for new-hire training is an unreimbursed employee expense. The miscellaneous business expense deduction, which includes unreimbursed employee expenses, to which petitioner is entitled is deductible on petitioner's Schedule A, Itemized Deductions. Sec. 162(a); see also sec. 1.162-17, Income Tax Regs. As an itemized deduction, it is subject to the 2-percent floor; that is, only the amount in excess of 2-percent of petitioner's adjusted gross income may be deducted. Sec. 67(a); sec. 1.67-1T(a)(1)(i), Temporary Income Tax Regs., 53 Fed. Reg. 9875 (Mar. 28, 1988). Thus, we find that respondent’s determination denying petitioner’s deductions was made in error. We hold that the expense petitioner incurred for new-hire training was a deductible unreimbursed business expense. Reviewed and adopted as the report of the Small Tax Case Division.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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