Sandra L. McBrayer - Page 3




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          Car and truck expenses                       $ 1,514                        
          Depreciation                                 573                            
          Utilities                                    1,714                          
          Other expenses:                                                             
               Uniform/dry cleaning/rental   $8,221                                   
               Luggage destroyed traveling   530                                      
               maintenance of residence while                                         
               out of town                   1,110                                    
               Conferences                    2,100     11,961                        
          Total                                         15,762                        

               In a notice of deficiency dated October 24, 1997, respondent           
          disallowed $9,861 of the following Schedule C expenses:  (1)                
          Uniform/dry clean/rental--$8,221; (2) luggage destroyed while               
          traveling--$530; and (3) maintenance of residence while out of              
          town--$1,110.                                                               
               Deductions are a matter of legislative grace, and a taxpayer           
          seeking a deduction must establish her entitlement to the                   
          deduction claimed.  New Colonial Ice Co. v. Helvering, 292 U.S.             
          435, 440 (1934).                                                            
               Section 162(a) allows a deduction for all the ordinary and             
          necessary expenses paid or incurred in carrying on a trade or               
          business.  Section 262, however, denies a taxpayer a deduction              
          for personal, living, or family expenses.                                   
          Rental Clothing Deductions                                                  
               Petitioner contends that she rented formal clothing on                 
          various occasions while lecturing.  Petitioner always inquired              
          about the occasion beforehand in order to be appropriately                  
          dressed.  Petitioner claimed deductions in the amount of $550 for           






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