Benjamin O. & Linda L. Agbaniyaka - Page 15




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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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