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must show the relationship between the expenditures and the
employment. See Evans v. Commissioner, T.C. Memo. 1974-267, affd.
557 F.2d 1095 (5th Cir. 1977). The taxpayer bears the burden of
substantiation. Hradesky v. Commissioner, 65 T.C. 87, 89 (1975),
affd. per curiam 540 F.2d 821 (5th Cir. 1976). Section 6001 and
the regulations promulgated thereunder require taxpayers to
maintain records sufficient to permit verification of income and
expenses. As previously noted, the Court may in some
circumstances estimate the amount of a deduction to which the
taxpayer is otherwise entitled. Cohan v. Commissioner, supra at
543-544.
Petitioners deducted $5,625 for uniforms for the taxable year
and stipulated that the uniforms Mr. Harrell wore were washed and
ironed at petitioners’ home. 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.
Mr. Harrell, in his position with United Parcel Service, was
required to work in a clean uniform every day. Mrs. Harrell
washed and ironed Mr. Harrell’s work uniforms at home. The
employer provided the uniforms but did not reimburse Mr. Harrell
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