Benjamin O. & Linda L. Agbaniyaka - Page 12

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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-               

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