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We now turn to the amount of the excess unreimbursed employee
and other miscellaneous expenses deduction to which petitioners
are entitled. On their return, petitioners claimed a deduction
for excess unreimbursed employee and other miscellaneous expenses
of $17,600. After considering the 2-percent floor, petitioners
claimed a deduction for excess unreimbursed employee and other
miscellaneous expenses of $15,834. Of this amount, respondent
does not dispute that petitioners are entitled to a deduction of
$690 for unreimbursed employee expenses--union dues. The
remaining components of the claimed deduction are uniforms
($5,625), supplies and equipment ($3,510), job search expenses
($4,800), telephone expenses ($2,850), and tax preparation fees
($125). Respondent disallowed the deduction for all of these
components.
Section 162(a) allows a deduction for ordinary and necessary
business expenses paid or incurred during the taxable year in
carrying on any trade or business. For an expense to be
“ordinary” the transaction that gives rise to it must be of a
common or frequent occurrence in the type of business involved.
Deputy v. du Pont, 308 U.S. 488, 495 (1940). To be “necessary” an
expense must be “appropriate and helpful” to the taxpayer’s
business. Welch v. Helvering, supra at 290 U.S. at 113-114. The
performance of services as an employee constitutes a trade or
business. See sec. 1.162-17(a), Income Tax Regs. The employee
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