- 5 -
looking at the date, I believe that I was in Washington going to
a White House event." The receipts contained no description of
the merchandise which was either rented or purchased.2
Petitioner was also unable to recall what type of formal wear the
receipts represented. The third receipt proffered by petitioner
was undated and did not include the name of the business.
Accordingly, we find that petitioner did not adequately
substantiate her claimed expenses and does not qualify for a
clothing deduction under section 162(a). Upon the basis of the
record, we hold that petitioner is not entitled to deduct
clothing rental expenses for the 1994 tax year.
Section 165(a) Deduction--Luggage
On her 1994 Federal income tax return, petitioner claimed a
Schedule C expense deduction in the amount of $530 for "luggage
destroyed [while] traveling".
At trial, petitioner testified that the luggage was not
destroyed, but had been stolen at Reagan National Airport.
Petitioner testified that she placed two pieces of luggage
outside of a bathroom stall at Reagan National Airport in 1994
and that when she came out of the stall, the luggage was gone.
2
One of these receipts, dated Apr. 15, 1994, listed the
transaction as a sale.
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