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Respondent determined a deficiency in petitioner’s Federal
income tax of $3,319 for the taxable year 2000.
The issue for decision is whether petitioner is entitled to
deduct $26,385 for job expenses and other miscellaneous
deductions.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Chicago, Illinois, on the date the petition was filed in this
case.
Petitioner was a financial consultant who was employed by
Merrill Lynch, Pierce, Fenner & Smith (Merrill Lynch) during the
taxable year 2000. During the year in issue, Merrill Lynch had a
reimbursement policy which stated:
[petitioner] * * * [is] entitled to be reimbursed for
certain limited expenses, but * * * [is] also expected to incur
expenses necessary to the job for which he would not be
reimbursed. Such expenses, ordinary in this business,
include travel and transportation, as well as promotional
and entertainment expenses, incurred in calling on customers
of Merrill Lynch for the purpose of creating sales through
investment discussions.
During taxable year 2000, petitioner requested reimbursement for
expenses of $4,866.38 incurred in furtherance of his job.
Merrill Lynch reimbursed petitioner for all of the requested
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