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The clothing items petitioners claimed as business expenses
include hosiery, exercise wear, warmup suits, denim clothing,
athletic shoes, and jazz shoes. At trial, Paula testified that
these items were necessary to teach aerobics and jazz dance. She
also testified that she does not wear the clothing "around the
house." The fact that Paula chose not to wear the clothing when
she was away from the school does not establish that such
clothing is not suitable for her private and personal wear. See
Hynes v. Commissioner, supra at 1291. It is relatively common
for people to wear warmup clothes, exercise wear, and athletic
shoes of the type purchased by petitioners while engaged in a
wide variety of casual or athletic activities. We, however, find
that the jazz shoes are not suitable for general or personal wear
and hold that petitioners may deduct the cost of this item as a
business expense. Petitioners presented no evidence that the
other clothing purchased for Paula's business was not adaptable
for wear outside the workplace. Therefore, we conclude that all
items of clothing at issue, except the jazz shoes, are suitable
for general or personal wear and hold that petitioners are not
entitled to deduct the costs of those items.
Chartering Activity
Section 183(a) provides generally that, if an activity is
not engaged in for profit, no deduction attributable to the
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