Chrys L. Udoh - Page 7




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               Petitioner deducted $728 for "Clothing, Shoes and                      
          Maintenance" in 1994.  Petitioner testified these expenses were             
          incurred for suits, blazers, shoes, and dry cleaning so that he             
          may dress in an acceptable manner in the insurance business.  The           
          expense of uniforms is deductible under section 162(a) if:  (1)             
          The uniforms are of a type specifically required as a condition             
          of employment; (2) the uniforms are not adaptable to general                
          usage as ordinary clothing; and (3) the uniforms are not so worn.           
          See Yeomans v. Commissioner, 30 T.C. 757, 767-769 (1958); Beckey            
          v. Commissioner, T.C. Memo. 1994-514.  It is clear from                     
          petitioner's testimony that the articles of clothing claimed as             
          expenses were adaptable to general use.  Therefore, petitioner's            
          clothing expenses are not deductible.  The remaining expenses for           
          dry cleaning likewise constitute personal expenses and are not              
          deductible under section 162.  See sec. 262.                                
               Petitioner deducted approximately $15,529 for his legal                
          education expenses on his Schedules C for tax years 1994 and                
          1995.  Included in this amount is the cost of travel to                     
          California for the taking of law school examinations, examination           
          fees, tuition, books, lodging, and meals.  Petitioner combined              
          some of these expenses with other expenses on his Schedules C               
          and, therefore, the amounts claimed are estimates.  At trial,               
          petitioner testified he incurred an estimated $10,610 in                    
          educational expenses.  The only documentation petitioner                    





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