Charles E. Townsend - Page 8

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          establishing his entitlement to any of the deductions that he is            
          claiming.6                                                                  
          Claimed Medical and/or Dental Expenses                                      
               Petitioner presented no evidence and advances no argument              
          with respect to the medical and/or dental expenses for which he             
          claims a deduction.                                                         
               On the record before us, we find that petitioner has failed            
          to carry his burden of establishing that he is entitled for his             
          taxable year 2002 to the deduction that he claims for medical               
          and/or dental expenses.                                                     
          Claimed Charitable Contributions                                            
               Section 170(a) allows a deduction for any charitable contri-           
          bution, as defined in section 170(c), that is made during the               
          taxable year.  A taxpayer claiming a deduction under section 170            
          must satisfy certain requirements prescribed by regulations                 
          promulgated under that section.  See sec. 1.170A-13, Income Tax             
          Regs.                                                                       
              In support of his position that he is entitled for his                 
          taxable year 2002 to a deduction of $980 for charitable contribu-           

               6In addition to respondent’s concession that petitioner paid           
          union dues of $646, see supra note 5, respondent concedes that              
          during the year at issue petitioner paid a tax preparation fee of           
          $175.  Respondent’s concessions will not affect the deficiency              
          determined in the notice unless we were to sustain petitioner’s             
          position with respect to his claimed expenditures for the use of            
          his automobile, lodging, meals, unidentified travel purposes, or            
          unidentified business purposes.  That is because of the two-                
          percent floor imposed by sec. 67(a).                                        





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