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On the record before us, we find that petitioners have
failed to carry their burden of establishing that they are
entitled for each of their taxable years 2002 through 2004 to the
deduction under section 162(a) that they claim for union dues.
Based upon our examination of the entire record before us,
we find that petitioners have failed to carry their burden of
establishing that they are entitled for each of their taxable
years 2002 through 2004 to the deduction under section 162(a)
that they claim for unreimbursed employee expenses.
Claimed Schedule C Net Loss
It is petitioners’ position that they are entitled for each
of their taxable years 2001 through 2004 to the Schedule C net
loss that they claimed for each such year. In support of that
position, petitioners argue that they are entitled to (1) cost of
goods sold of $12,284, $5,314, and $3,370 in excess of the
amounts of cost of goods sold allowed by respondent for petition-
ers’ respective taxable years 2002 through 2004;11 (2) deprecia-
tion of $2,496, $1,498, $898, and $898 claimed for the Dodge van
for petitioners’ respective taxable years 2001 through 2004;
(3) auto insurance premiums of $942, $942,12 $917, and $860
claimed for petitioners’ respective taxable years 2001 through
11See supra note 3.
12In the 2002 Schedule C, petitioners claimed insurance
expenses totaling $1,110. See supra note 4.
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Last modified: November 10, 2007