- 7 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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