Kevin J. and Crystal A. Shoemaker - Page 25

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         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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