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amount. The Court will again bear heavily on petitioner and
allow him a $30 deduction for coveralls for each of the 1992 and
1993 years.
Petitioner also claimed as a deduction amounts contributed
as dues to the labor union of which he is a member. At trial,
petitioner testified that he spent up to $30 per month on union
dues. This Court found petitioner to be a credible witness, and
we are satisfied that some amount was contributed to petitioner’s
labor union. Consistent with our treatment of the work boots and
coveralls, a deduction of $15 per month for union dues is allowed
for 1992 and 1993. Petitioner is entitled to an additional
deduction for supplemental union dues paid in 1992 of $714.65,
which was substantiated by two “employee [statements]”.
The foregoing miscellaneous business expense deductions to
which petitioner is entitled are all deductible on petitioner’s
Schedule A, Itemized Deductions. As itemized deductions, they
are subject to the 2-percent limitation. Sec. 67(a).
Petitioner’s outlay for tools poses a more difficult
problem. Petitioner did not make an election under section 179
that would permit him to deduct currently up to $10,000 of the
cost of depreciable property in the year it was placed in
service. Having made no section 179 election, petitioner is
within the general rules regarding depreciation. See Alisobhani
v. Commissioner, T.C. Memo. 1994-629.
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