2. The crucial reason for determining whether an item is deductible as an expense under 162 or under 212 is that

1. production-of-income expenses are not deductible.
2. 162 business expenses usually are deductions for A.G.I., while 212 production-of-income expenses usually are deductible for A.G.I also.

c. 162 business expenses usually are deductions for A.G.I., while 212 production-of-income expenses usually are not deductible from A.G.I. as miscellaneous itemized deductions.

d. 162 business expenses are deductions from A.G.I., while 212 production-of-income expenses are deductions for A.G.I.

e. it resolves certain ownership questions.