Congress hates employees--that's a fact of life that a worker learns the hard way in the case of Alley v. Commissioner, (TC Summary Opinion 2006-4) that we discuss this week. Mr. Alley had a "creative" way of getting around the fact that Section 62 does not allow employee business deductions to be taken in computing adjusted gross income. Unfortunately for Mr. Alley, the Tax Court did not appreciate his creativity.


The case offers an option to look at the overall structure of where deductions are taken and the controlling provisions, so it useful beyond just the employee business expense context. The supporting materials can be downloaded

here.


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