- 13 -
respondent has allowed petitioner a $3,382 professional supplies
deduction and a $2,750 depreciation deduction (calculated by
dividing the remaining cost basis of equipment, $13,750,5 by a 5-
year life of the asset). Petitioner has not presented proof or
argument to support a deduction in excess of what respondent has
allowed.
To support a stage clothes deduction,6 petitioner submitted
receipts totaling $695.11, representing purchases of various
stage clothes items for which respondent has not allowed any
amount. The receipts reflect the purchases of silk boxers,
leather pants, men’s underwear, hats, and a vest. Clearly the
underwear does not qualify as a business expense. As to the
remaining clothes items, we find that the majority of them are
adaptable for general and personal wear and, therefore, are not a
deductible employee business expense. Some of the more “flashy”
and “loud” items, however, might not be acceptable ordinary wear.
Although the receipts do not indicate which items fall into that
category, we allow petitioner a $200 deduction for stage clothes.
See Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930).
The claimed agent’s commission expense is supported only by
petitioner’s testimony and relates to rent payments petitioner
5 This number is the original cost basis, $17,132, less the
amount respondent conceded as deductible in 1991, $3,382.
6 Petitioner did not claim a separate deduction for stage
clothes but most likely included it as part of another category.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011