Juvy Lyn Andrade Te Eng Fo - Page 3




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          other court, and this opinion shall not be treated as precedent             
          for any other case.                                                         
               Respondent determined a $3,195 deficiency in petitioner’s              
          Federal income tax for 2002.                                                
               The issue for decision is whether petitioner is entitled to            
          the deduction for unreimbursed employee expenses claimed on                 
          Schedule A, Itemized Deductions, of her 2002 return.                        
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  Petitioner resided in New York, at the time that the                
          petition was filed.                                                         
               In 2002, the taxable year in issue, petitioner was employed            
          as a family physician by the Fridley Children’s and Teenagers’              
          Medical Center, P.A., in Fridley, Minnesota.  Petitioner worked             
          full time at the medical center from November of 2000 to November           
          of 2002.  Petitioner has been unemployed and seeking employment             
          as a physician since November of 2002.                                      
               Petitioner filed a Federal income tax return for 2002 on               
          which she reported total income of $117,007 and adjusted gross              
          income of $116,679.                                                         
               Petitioner attached to her return a Schedule A.  Petitioner            
          claimed total itemized deductions of $44,245, which included                
          unreimbursed employee expenses of $15,059 before diminution by              
          the 2-percent floor prescribed by section 67.                               







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