- 17 -
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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Last modified: May 25, 2011