- 11 -
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).
We find that the majority of the clothes and the shoes are
adaptable for general and personal wear and, therefore, are not a
deductible ordinary and necessary business expense. However, a
few of the items are quite formal and not adaptable for general
and personal wear, such as the sequined items and formal dresses.
We hold that petitioners are entitled to a deduction of $218.
Sec. 162(a); see Fisher v. Commissioner, 23 T.C. 218 (1954),
affd. 230 F.2d 79 (7th Cir. 1956).
Travel Expense on Schedule C
Petitioners claimed a deduction for travel on Schedule C in
the amount of $1,180 for airfare to Bulgaria for Mr. Popov.
During 1993, Mr. Popov was a law student. He also started a
business called the Intellectual Marriage Club, whose goal was to
introduce educated Eastern Europeans to Americans. Before her
visit to the United States, Mr. Popov’s mother placed
advertisements for him, but only in the newspapers in Sofia where
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011