- 24 - concluded above that we shall not rely upon document one or document two to establish petitioners’ position with respect to any of the claimed expenses, including the tool expenses for which they claim a deduction for 2002. In any event, the total amount of tool expenses that petitioners claimed in document two is $277.18, the amount that respondent allowed.23 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 for tool expenses in excess of the amount allowed by respondent. 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 and the concession of respondent, Decision will be entered under Rule 155. 23Although the total amount of tool expenses that petition- ers claim in document two is $277.18, the amount that respondent allowed, the claimed tool receipts appear to total $278.54, which is $1.36 more than the tool expense amount that respondent allowed. Had respondent not allowed petitioners tool expenses of $277.18, on the record before us, we would not have been able to find that petitioners’ tool expenses during 2002 totaled that amount. See supra note 21.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Last modified: May 25, 2011