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maintained a checking account for his claimed arts and crafts
business (claimed business checking account), even though that
account had a zero balance. At least during each of the years
2001, 2002, and 2003, Mr. Agbaniyaka paid certain bank service
charges to maintain the claimed business checking account.
Petitioners timely filed Form 1040, U.S. Individual Income
Tax Return (return), for each of their taxable years 2001 (2001
return), 2002 (2002 return), 2003 (2003 return), and 2004 (2004
return). Petitioners included Schedule A-Itemized Deductions
(Schedule A) as part of the 2001 return (2001 Schedule A), the
2002 return (2002 Schedule A), the 2003 return (2003 Schedule A),
and the 2004 return (2004 Schedule A). Petitioners also included
Schedule C as part of the 2001 return (2001 Schedule C), the 2002
return (2002 Schedule C), the 2003 return (2003 Schedule C), and
the 2004 return (2004 Schedule C). In each such Schedule C,
petitioners showed the “Principal business or profession, includ-
ing product or service” as “AFRICAN ARTS & CRAFT”2 and the “Busi-
ness name” as “WAND AFRICA CONTEMPORARY IMPORTS”.
In the 2001 Schedule A, petitioners claimed under the
heading “Job Expenses and Most Other Miscellaneous Deductions”
$4,792 of “Unreimbursed employee expenses” (unreimbursed employee
expenses), which they identified in that schedule as “UNION DUES
2In the 2002 Schedule C, petitioners showed the “Principal
business or profession, including product or service” as “AFRICAN
ARTS, CRAFTS”.
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Last modified: November 10, 2007