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Claimed Union Dues
A taxpayer is entitled to deduct expenses for union dues if
such expenses constitute ordinary and necessary expenses paid or
incurred during the taxable year in carrying on a trade or busi-
ness.20 Sec. 162(a).
The only evidence that petitioners introduced into the
record relating to petitioners’ claimed union dues is document
two. We concluded above that we shall not rely upon document two
to establish petitioners’ position with respect to any of the
claimed expenses, including the union dues for which they claim a
deduction for 2002. In any event, the total amount of union dues
that petitioners claimed in document two is $1,865.39, the amount
that respondent allowed.
On the record before us, we find that petitioners have
failed to carry their burden of establishing that they are enti-
tled for their taxable year 2002 to the deduction that they claim
19(...continued)
they are claiming for 2002 for such clothing. The receipts that
petitioners introduced into the record relating to the items of
clothing in question total only $385.48.
20It is not altogether clear whether petitioners are claim-
ing that they are entitled to deduct an amount for union dues in
excess of $1,865.39, the amount allowed by respondent. The
record does not disclose the amount that petitioners claimed as a
deduction for union dues in petitioners’ 2002 return. On brief,
respondent does not indicate that there is any amount of union
dues at issue. However, we shall proceed on the assumption that
petitioners are claiming a deduction for their taxable year 2002
for an unspecified amount of union dues in excess of the amount
allowed by respondent.
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