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189 (1999).
Claimed Unreimbursed Employee Expenses
It is petitioners’ position that, prior to the application
of the two-percent floor imposed by section 67(a), they are
entitled for each of their taxable years 2002 through 2004 to
deduct the $2,300 of unreimbursed employee expenses that they
claimed in each of the 2002 Schedule A, the 2003 Schedule A, and
the 2004 Schedule A.8 According to petitioners, they paid that
amount during each of those years for certain unidentified
educational expenses of Mr. Agbaniyaka (claimed educational
expenses)9 and for certain unidentified union dues of Mr.
Agbaniyaka and Ms. Agbaniyaka.
We turn first to petitioners’ claimed educational expenses.
Petitioners contend that during each of the years 2002 through
2004 Mr. Agbaniyaka attended a course on trusts and estates and
certain other unidentified courses and that he paid certain
unidentified expenses relating to those courses. According to
8Respondent does not dispute Schedule A unreimbursed em-
ployee expenses that petitioners are claiming for their taxable
year 2001.
9Although petitioners contend that the claimed educational
expenses are for professional books, accounting journals, and
transportation to and from certain schools, on the record before
us, we find that petitioners have failed to carry their burden of
establishing the names of those claimed professional books and
accounting journals, the mode of transportation that petitioners
contend Mr. Agbaniyaka used to travel to and from certain
schools, and the respective amounts of those unidentified ex-
penses.
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