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Commissioner, 503 U.S. 79, 84 (1992). Petitioner was required to
maintain records sufficient to establish the amount of any
deduction claimed. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
Petitioner claims3 the following deductions: (1) Medical
and/or dental expenses of $4,880 prior to the application of the
7.5-percent floor imposed by section 213(a); (2) charitable
contributions of $980; and (3) job expenses of $16,874 prior to
the application of the two-percent floor imposed by section 67(a)
that consisted of (a) automobile expenses of $5,844, (b) lodging
expenses of $999.84 that petitioner included as part of the
$6,884 claimed in the travel expense category in the 2002 Form
2106-EZ, (c) meal expenses of $3,420,4 (d) the balance of
$5,884.16 that petitioner included as part of the $6,884 claimed
in the travel expense category in the 2002 Form 2106-EZ,
(e) unidentified business expenses of $950, and (f) union dues of
$188 in excess of those allowed by respondent.5 Respondent
counters that petitioner has failed to carry his burden of
3Although the Court ordered petitioner to file a posttrial
brief, he failed to do so.
4In the 2002 Form 2106-EZ, petitioner claimed total meal
expenses of $6,840, which he reduced by 50 percent, as required
by sec. 274(n).
5Respondent concedes that during the year at issue peti-
tioner paid $646 of the $834 of union dues that petitioner
claimed in the 2002 Schedule A included as part of petitioner’s
2002 tax return.
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