Timothy J. Burke - Page 17

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          at 217.  Petitioner has failed to meet his burden to come forward           
          with specific facts showing a genuine issue of material fact                
          exists.  Petitioner has not provided adequate substantiation of             
          the expenses or provided any explanation or description of his              
          entitlement to deduct the expenses.  Accordingly, respondent is             
          entitled to summary judgment.                                               
               To reflect the foregoing,                                              

                                                 An appropriate order and             
                                            decision will be entered.                 





























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