Charles E. Townsend - Page 16

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         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 certain                
         unidentified business expenses.                                              
              Claimed Union Dues                                                      
              In support of his position that he is entitled for his                  
         taxable year 2002 to deduct $188 of union dues in excess of the              
         amount allowed by respondent,10 petitioner relies on document two.           
         Document two purports to list union dues totaling $645.50 that               
         petitioner claims he paid in 2002 to three different unions.                 
         Petitioner did not offer any other evidence, such as canceled                
         checks, to corroborate that claim.  In any event, the total                  
         amount of union dues that petitioner claims in document two is               
         $645.50, which is less than the amount conceded by respondent.               
              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 union dues             
         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.                                      



               10See supra note 5.                                                    





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