- 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