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that State income taxes are allowed as a deduction for the
taxable year within which they are paid or accrued. Respondent
conceded that petitioner was entitled to a $14,513 State income
tax deduction. Petitioner did not produce any evidence at trial
to substantiate the additional claimed $1,236 State income tax
deduction. Therefore, petitioner cannot deduct the additional
$1,236.
2. Unreimbursed Employee Expenses
Petitioner claimed a $3,376 deduction for unreimbursed
employee business expenses incurred during 2000. Pursuant to
section 162(a), a taxpayer may deduct all of the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business including a trade or business as
an employee. Lucas v. Commissioner, 79 T.C. 1, 6 (1982).
Petitioner did not produce any evidence at trial to substantiate
the claimed unreimbursed employee business expenses.
Accordingly, we sustain respondent’s determination regarding the
unreimbursed employee business expenses.
Petitioner attached to her posttrial brief documents to
support her claimed deduction for unreimbursed employee expenses.
Evidence must be submitted at trial; documents attached to briefs
and statements made therein do not constitute evidence and will
not be considered by the Court. Rule 143(b); Evans v.
Commissioner, 48 T.C. 704, 709 (1967), affd. per curiam 413 F.2d
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