Ronnie O. and G. June Craft - Page 9

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         necessary expenses of his trade or business of being a Craft-                
         Barnett employee.                                                            
               C.  Proper Placement of Deductions                                     
               After concluding that the expenses are properly deductible             
         by petitioner, the next issue is whether petitioner properly                 
         deducted the expenses on his Schedule C or whether the expenses              
         are subject to the 2-percent limitation of section 67 and the                
         limitation in section 68.                                                    
               Section 62 lists the deductions from gross income which are            
         allowed for the purpose of computing adjusted gross income.                  
         Section 62(a)(1) provides the general rule that trade or business            
         deductions are allowed for the purpose of computing adjusted                 
         gross income “if such trade or business does not consist of the              
         performance of services by the taxpayer as an employee.”                     
         Expenses of employment, if incurred under a reimbursement                    
         arrangement with the employer, are deductible in computing the               
         employee’s adjusted gross income.  See sec. 62(a)(2).  Otherwise,            
         individuals with unreimbursed trade or business expenses from                
         their employment must deduct these expenses subject to the 2-                
         percent limitation of section 67.  Gonzalez v. Commissioner, T.C.            
         Memo. 1997-430.  These expenses may be further reduced pursuant              
         to section 68 if the individual’s “adjusted gross income exceeds             
         the applicable amount”.  Sec. 68(a).                                         








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