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for an unspecified amount of union dues in excess of the amount
allowed by respondent.
Claimed Tool Expenses
A taxpayer is entitled to deduct expenses for tools if such
expenses constitute ordinary and necessary expenses paid or
incurred during the taxable year in carrying on a trade or busi-
ness.21 Sec. 162(a).
The evidence that petitioners introduced into the record
relating to petitioners’ claimed tool expenses consists of docu-
ment one, document two, nine receipts that appear to total
$278.54 that petitioners claim Mr. Shoemaker spent for tools
purchased during 2002,22 and the testimony of Mr. Shoemaker. We
21It is not altogether clear whether petitioners are claim-
ing that they are entitled to deduct an amount for tool expenses
in excess of $277.18, the amount allowed by respondent in the
notice. The record does not disclose the amount that petitioners
claimed as a deduction for tool expenses in petitioners’ 2002
return. On brief, respondent does not indicate that there is any
amount of tool expenses at issue. However, at trial, petitioners
presented receipts that appear to total $278.54 (claimed tool
receipts) that petitioners claim Mr. Shoemaker spent for tools
purchased during 2002, which is greater than the amount allowed
by respondent. Two of the claimed tool receipts that petitioner
introduced into the record are illegible in certain material
respects, and one of those illegible receipts includes the
purchase of dog food. Another claimed tool receipt is for a
“camp chair”. We shall proceed on the assumption that petition-
ers are claiming a deduction for their taxable year 2002 for an
unspecified amount of tool expenses in excess of the amount
allowed by respondent.
22The parties stipulated that the receipts were from Sears,
Tractor Supply Company, Rite Aid, Total Image, and Quality Farm
and Country. However, one of the receipts also is from Lowe’s.
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