- 6 -
Certain business deductions described in section 274,
however, are subject to strict substantiation. No deduction is
allowed with respect to: (1) Any traveling expense (including
meals and lodging while away from home); (2) any item with
respect to an activity which is of a type generally considered to
constitute entertainment, amusement, or recreation; (3) any
expense for gifts; or (4) the use of any “listed property”, as
defined in section 280F(d)(4), unless certain elements are
substantiated. See sec. 274(d). Passenger automobiles are
listed property under section 280F(d)(4)(A)(i).
Petitioners presented no records at trial to substantiate
any of the expenses at issue. Furthermore, they provided little
testimony from which we could determine their entitlement to
deductions for the expenses.
Petitioner testified that he took three sales-training
courses in 1996 at his own expense; however, he did not provide
any information as to the amount of his expense. With regard to
the expenses petitioner claimed for uniforms and cleaning,
petitioner testified that the expenses were for business suits he
was required to wear to his job. The expense of uniforms is
deductible under section 162(a) only if: (1) The uniforms are of
a type specifically required as a condition of employment; (2)
the uniforms are not adaptable to general usage as ordinary
clothing; and (3) the uniforms are not so worn. See Yeomans v.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011