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Commissioner v. Lundy, 516 U.S. 235, 252 (1996), quoting
Badaracco v. Commissioner, 464 U.S. 386, 398 (1984).
Accordingly, petitioners' appeal for relief must, in this
instance, be addressed to their elected representatives.4
Conclusion
In view of the foregoing, we hold that petitioners are not
entitled to the deductions in issue. Respondent’s determination
is therefore sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issues,
Decision will be entered for
respondent.
4 Regarding petitioners’ concern about parity, it must be
acknowledged that differences do exist between the treatment of
employees and the self-employed for tax purposes. However, our
disposition of the disputed issues in the present case would have
been no different if petitioner had been an employee rather than
a self-employed individual.
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