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Issue (5): Union Dues - 1993
Petitioner claimed a deduction for union dues in the amount
of $360 on his Schedule A for 1993.
Documentary evidence introduced by petitioner at trial
establishes that petitioner paid union dues to Local 998 of the
Amalgamated Transit Union (AFL-CIO) in the amount of $331.65 in
1993. Petitioner contends that his exhibit contains a
typographical error and that the amount actually paid was the
amount claimed on his return. However, the matter is moot
because of the 2-percent floor on miscellaneous itemized
deductions prescribed by section 67.
Section 67(a) provides that in the case of an individual,
miscellaneous itemized deductions are allowable only to the
extent that the aggregate of such deductions exceeds 2 percent of
the individual's AGI. A deduction for union dues constitutes a
miscellaneous itemized deduction. Sec. 67(b). In petitioner's
case, the deduction for union dues is petitioner's only
miscellaneous itemized deduction in 1993, and 2 percent of
petitioner's AGI for that year exceeds the amount that petitioner
seeks to deduct. Accordingly, no deduction is allowable.
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