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estimate, the Court will closely scrutinize a taxpayer whose
inexactitude is of his own making. Cohan v. Commissioner, supra;
DeMauro v. Commissioner, T.C. Memo. 1994-460, affd. without
published opinion 82 F.3d 404 (3d Cir. 1996). Given that Mrs.
Whalley is a police lieutenant, we can reasonably infer that she
incurred cleaning expenses for her uniforms and was required to
pay union dues. However, with respect to the purported purchase
of Mrs. Whalley's police uniforms, no evidence was presented to
establish that the Hayward Police Department required police
officers to purchase their own uniforms. Petitioners' failure to
submit any records to substantiate such expenses weighs heavily
against them. Accordingly, under Cohan, we allow petitioners to
deduct $300 for 1992 for the cost of dues and cleaning uniforms.
However, we sustain respondent's determination as to the $3,790
balance.
B. Books and Motivational Tapes
For 1991 and 1992, Mrs. Whalley deducted $36 and $467,
respectively, for motivational tapes, cassettes, and books, such
as The Confident Woman; as well as magazines and newspapers, such
as Self, Working Woman, and the Valley Times.
Petitioners have failed to establish how such expenses are
connected to Mrs. Whalley's job as a police officer, and not
merely expenses for her own personal growth and entertainment.
Thus, we find that such amounts constitute personal expenditures
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