-8-
arguendo, that Mr. Bradley could substantiate the time, place,
and business purpose for each use of his car, only $876.38
($3,567.74 amount substantiated less $2,691.36 of reimbursable
expenses) of his vehicle expenses would be deductible. Register
v. Commissioner, T.C. Memo. 1988-390 (deduction allowed only to
the extent the taxpayer can substantiate expenses in excess of
the amount for which he was reimbursed).
Mrs. Bradley claimed a deduction for actual vehicle expenses
in 1991 of $3,549. She was reimbursed by her employer in the
amount of $3,085.56 (11,428 business miles multiplied by 27 cents
per mile). Thus, any vehicle expenses in excess of $3,085.56 are
nonreimbursable and potentially deductible. However,
Mrs. Bradley substantiated the amount of her vehicle expenses by
presenting invoices and canceled checks only in the amount of
$705.75. Even if Mrs. Bradley could substantiate the time,
place, and business purpose for each use of her car, no portion
of her vehicle expenses would be deductible. Id.
Petitioners have therefore established entitlement to a
deduction for vehicle expenses in the amount of $876.38, which is
less than the $1,773 deduction allowed by respondent. Because
they have failed to prove that the determination is erroneous, we
sustain respondent on this issue.
b. Uniform Expenses
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
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