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paid those expenses. Those expenses, however, do not constitute
other miscellaneous deductions and in fact are medical expenses,
as respondent argues.
Section 873(a) provides generally that, in the case of a
nonresident alien, deductions are allowed only if, and to the
extent that, such expenses are connected with income that is
effectively connected with the conduct of a trade or business
within the United States with the apportionment and allocation of
the allowable deductions as provided by regulations.
Additionally, section 873(b) provides exceptions to the general
rule of section 873(a) and allows deductions for certain expenses
that are not effectively connected with a trade or business
within the United States. The allowable deductions are: (1)
Casualty and theft losses under section 165, (2) charitable
contributions under section 170, and (3) personal exemptions
under section 151. Medical and dental expenses incurred by a
nonresident alien are not included as an exception to the general
rule. That is why, therefore, Schedule A for Form 1040NR does
not provide for deduction of medical and dental expenses. The
job expenses and most other miscellaneous deductions, although
not specified as being deductible under section 873(b), are,
nonetheless, deductible under section 873(a) because such
expenses are effectively connected with the conduct of a trade or
business within the United States. Therefore, with respect to
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