Donald Victor Teschner - Page 11

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          Cost Recovery System (MACRS), which was introduced into law by              
          the Tax Reform Act of 1986, Pub. L. 99-514, sec. 201(a), 100                
          Stat. 2085, 2121-2137.  A depreciation deduction for tangible               
          property is calculated by using the applicable depreciation                 
          method, recovery period, and convention.  Sec. 168(a).                      
               No deduction is allowed for personal, living, or family                
          expenses.  Sec. 262.  In evaluating whether certain expenses are            
          personal or business in nature, the courts have found that some             
          expenses are so “inherently personal” that they are almost                  
          invariably held to come within the ambit of section 262.  Fred W.           
          Amend Co. v. Commissioner, 55 T.C. 320, 325-326 (1970), affd. 454           
          F.2d 399 (7th Cir. 1971).  It is well settled that clothing that            
          is suitable for general or personal wear does not qualify as a              
          business expense under section 162.  E.g., Green v. Commissioner,           
          T.C. Memo. 1989-599.  Such costs are not deductible even when it            
          has been shown that the particular clothes would not have been              
          purchased but for the employment.  Stiner v. United States, 524             
          F.2d 640 (10th Cir. 1975); Donnelly v. Commissioner, 262 F.2d 411           
          (2d Cir. 1959), affg. 28 T.C. 1278 (1957).                                  
               With the exception of a $200 deduction for stage clothes,              
          see infra pp. 12-13, petitioner is not entitled to deductions for           
          any of his claimed expenses in excess of what respondent has                
          allowed. For the automobile, office supplies, research, and                 
          travel expenses, petitioner did not submit documentary or                   

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