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proving entitlement to any deduction claimed. INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992). Petitioners were required
to maintain records sufficient to establish the amount of any
deduction claimed. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
As we understand their position, petitioners contend that,
prior to the application of the two-percent floor imposed by
section 67(a), they are entitled to deduct $27,752.75 for the use
of their automobile (which includes $1,186.75 for parking fees
and tolls), $8,576 for meals, $498.34 for two cellular telephones
(cell phones), $175.76 for a pager, $444.42 for certain items of
clothing, an unspecified amount in excess of the amount allowed
by respondent for union dues, and an unspecified amount in excess
of the amount allowed by respondent for tools.4 Respondent
counters that petitioners have failed to carry their burden of
establishing their entitlement to any of the deductions that they
are claiming.
A taxpayer is entitled to deduct all the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business, sec. 162(a), including “travel-
4We note that, prior to the application of the two-percent
floor imposed by sec. 67(a), the total (i.e., $39,589.84) of
(1) the respective total amounts of the different categories of
expenses that petitioners claim here (i.e., $37,447.27) and
(2) the amount of job expenses allowed by respondent in the
notice (i.e., $2,142.57) is greater than the total amount of job
expenses (i.e., $35,558) that petitioners claimed in the 2002
Schedule A prior to the reduction required by sec. 67(a).
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