Sohail S. Hussaini, T. C. Memo. 2025-82, filed 8/4/25, is a computer engineer who  says he ran up $46K in travel expenses between his home in IA and the top-secret military contractors’ hangouts in MD and NJ where he worked. (because he couldn’t teletubby).

Although Sohail had logs (which IRS disputes as unsubstantiated, includes out years, and fails Section 274 tests), Judge Rose E. (“Cracklin'”) Jenkins “concludes that the logs are not relevant evidence given the holding, discussed herein, that there is no statutory authorization for petitioner’s deduction of any travel expenses related to his employment during the [year at issue]. T. C. Memo. 2025-82, at p. 2, footnote 3.

Even if he had adequate proof, Sohail was a W-2 EE with no employer expense plan, hence Section 62(a)(1) put all unreimbursed employee expense deduction for year at issue on ice until 1/1/2026.

Except.

Section 62(a)(2)(A)–(C), (E), gives a deduction for government officials, performing artists, employer reimbursement plans, and military reservists.

Except.

“Petitioner suggested that he is entitled to the deduction allowed to Reservists. However, given that an employee of a company consulting on a military contract is not, by reason thereof, a Reservist, and petitioner has never been a Reservist, petitioner is not entitled to a deduction under section 62(a)(2)(E) for [year at issue]].” T. C. 2025-82, at pp. 3-4.

So Sohail joins Phoebe Jonas, for whom see my blogpost “Unqualified Performer,” 2/9/24, in the ranks of those cut by the Jobs Cut and Tax Act of 2017.