- 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.
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