Brian F. Nicely - Page 15

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          personal purposes.  In fact, petitioner acknowledged at trial               
          that he was wearing Rocky Wolverine boots.                                  
               On the record before us, we find that petitioner has failed            
          to carry his burden of establishing that he is entitled for his             
          taxable year 2002 to the deduction that he claims for clothes,              
          boots, and gloves.                                                          
               We have considered all of the parties’ contentions and                 
          arguments that are not discussed herein, and we find them to be             
          without merit, irrelevant, and/or moot.                                     
               To reflect the foregoing,                                              

                                             Decision will be entered for             

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