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personal. Therefore, we sustain respondent's determination with
respect to this deduction.
Petitioners claimed deductions for items such as musical
records, magazine subscriptions, and office supplies. The
musical records enabled Paula to conduct dance instruction in her
business. We find the expenses for jazz dance records to be
ordinary and necessary to Paula's business as a dance instructor.
Although petitioners claim a business purpose for the magazine
subscriptions, the types of magazines are so inherently personal
that we conclude they are not business expenses under section
162.3 Paula testified that the office supplies were necessary
for school. Petitioners, however, did not introduce evidence
that showed that the expenses relating to the office supplies
would not be reimbursed by Paula's employer. Therefore, we hold
that petitioners are entitled to deduct the cost of the musical
records and sustain respondent's disallowance of expenses
relating to the magazine subscriptions and office supplies.
Petitioners also claimed deductions for clothing expenses.
For the cost of clothing and maintaining such clothing to be
deductible as an ordinary and necessary business expense, it must
(1) be required or essential in the taxpayer's employment, (2)
not be suitable for general or personal wear, and (3) not be so
worn. Yeomans v. Commissioner, 30 T.C. 757, 767 (1958).
3 Petitioners claimed deductions for magazine subscriptions
to Highlights, a children's magazine; and Essence and Ebony,
magazines of style and entertainment.
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