Rick and Ruth Baime Richards - Page 24

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          was engaged in the actress-model activity with the requisite                
          profit objective.                                                           
               Mrs. Richards managed some aspects of this activity in a               
          businesslike fashion.  She had an agent and kept a journal of her           
          auditions and callbacks.  Moreover, Mrs. Richards has a long                
          history in the acting profession.  She has been in numerous                 
          plays, commercials, television shows, and a few movies.                     
          4. Actress-Model Expenses                                                   
               Expenses for the Academy Players Directory, agent fees,                
          photo session, and duplicate photos are all ordinary and                    
          necessary expenses of an actress-model activity.  Petitioners               
          submitted documentation to show that they incurred these expenses           
          in 1994, and, therefore, we find that petitioners are entitled to           
          deductions of $60, $262, $267, and $231, respectively for these             
               Petitioners claimed a deduction of $960 for miscellaneous              
          expenses for hair and wig preparation, cosmetics, clothing,                 
          alterations, cleaning, supplies, fur coat storage, gifts,                   
          supplies, and meals.  Petitioners did not offer any documentation           
          or testimony on the breakdown of how much was spent on each item.           
          Furthermore, some of these expenses are not deductible business             
          expenses.6  Therefore, without any help from the record, we                 

               6  It is well settled that clothing that is suitable for               
          general or personal wear does not qualify as a business expense             

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