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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
expenses.
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
(continued...)
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