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blouse. There was no dress code per se for physicians at the
medical center. When petitioner was seeing patients, she usually
wore either a scrub shirt or a lab coat over her blouse.
Petitioner did not wear suits or dresses while at work.
Petitioner did not purchase any scrubs or lab coats in 2002.
Petitioner’s State income tax liability was recomputed as a
result of the State audit, and she consented to the recalculated
liability. The result of the State audit was then forwarded to
the Internal Revenue Service (IRS) pursuant to an exchange
agreement between the IRS and the Minnesota Department of
Revenue.
Respondent mailed to petitioner a notice of deficiency in
which it was determined that petitioner had failed to fully
substantiate the aforementioned deduction claimed for
unreimbursed employee expenses. Accordingly, respondent reduced
$44,245 of Schedule A deductions to $33,605, disallowing
unreimbursed employee expenses totaling $10,640. Respondent
allowed the same $4,419 of the claimed $15,059 unreimbursed
employee expenses that were allowed by the State audit.
Petitioner disputed respondent’s deficiency determination by
timely filing a petition for redetermination; however, she did
not set forth any reason in her petition as to why she is
entitled to relief. Petitioner’s quarrel, as expressed at trial,
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