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establishment is also listed property, and, therefore, deductions
for the use of such property are also subject to the same
substantiation requirements. Sec. 280F(d)(4)(A)(ii) and (B).
Moreover, there is evidence in the record that petitioner's
employer, Intel Corp., had a reimbursement policy that would have
covered at least some of the expenses petitioner incurred in his
employment. There is no evidence that petitioner claimed
reimbursement from his employer for any of the expenses claimed
on the tax returns. The law is well settled that reimbursable
expenses for which an employee claims no reimbursement are not
deductible. Orvis v. Commissioner, 788 F.2d 1406 (9th Cir.
1986), affg. T.C. Memo. 1984-533. With respect to that portion
of petitioner's expenses relating to special clothing necessary
in his employment, the amount of which was not specified, this
Court has held that expenses for clothing used by an employee at
work that is suitable for ordinary wear, including expenses for
the purchasing and laundering of such clothing, constitute
personal expenses and are not deductible under section 262.
Barone v. Commissioner, 85 T.C. 462, 469 (1985), affd. without
published opinion 807 F.2d 177 (9th Cir. 1986). On the other
hand, shoes or clothing worn by an employee that are not
adaptable to personal use and are necessary for the employee's
safety and protection while at work are deductible as employee
business expenses. Kozera v. Commissioner, T.C. Memo. 1986-604.
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