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and Rule references are to the Tax Court Rules of Practice and
Procedure.
Respondent determined a $7,908 deficiency in petitioners’
2002 Federal income tax. The issues for decision are: (1) The
amount of petitioners’ loss from farming; and (2) the amount of
the excess unreimbursed employee and other miscellaneous expenses
deduction1 to which petitioners are entitled.
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. At the time they filed
the petition, petitioners resided in Katy, Texas.
Petitioners timely filed a joint Form 1040, U.S. Individual
Income Tax Return, for 2002 in which they claimed: (1) A loss
from farming, and (2) itemized deductions for excess unreimbursed
employee and other miscellaneous expenses. Respondent determined
that a portion of the amount claimed as a farm loss and the
entire amount claimed as itemized deductions for excess
unreimbursed employee and other miscellaneous expenses were not
1The excess unreimbursed employee and other miscellaneous
expenses deduction is claimed on Schedule A, Itemized Deductions.
The amount of the deduction equals the sum of: (1) Unreimbursed
employee expenses--job travel, union dues, job education, etc.;
(2) tax preparation fees; and (3) other expenses--investment,
safe deposit box, etc., less an amount equal to 2 percent (the 2-
percent floor) of the taxpayer’s adjusted gross income. See sec.
67(a).
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