Alan L. Levitt - Page 10




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              Petitioner testified that he had his shirts and the vests               
         provided by MGM dry cleaned.  He claimed that he paid $22 per                
         week to maintain the tuxedo shirts and $25 per week to clean the             
         vests.  However, petitioner provided one receipt of $3.85 for dry            
         cleaning.  We may estimate the amount of expenses, so long as                
         petitioner provides evidence upon which we can base an estimate.             
         Rodman v. Commissioner, 542 F.2d 845, 853 (2d Cir. 1976), affg.              
         T.C. Memo. 1973-277; Cohan v. Commissioner, 39 F.2d 540 (2d Cir.             
         1930).  Petitioner provided little evidence other than his vague,            
         undocumented testimony.  Nevertheless, we have no doubt he must              
         have incurred some expenses for cleaning the vests and shirts.               
         Using our best estimate, we allow $250 for dry cleaning.                     
              We find that petitioner is entitled to deduct $503.08 for               
         his uniform and dry cleaning expenses.  However, after                       
         concessions and our findings, petitioner’s itemized deductions               
         for 1994 do not exceed the standard deduction.  Sec. 63(c);                  
         Cotton v. Commissioner, T.C. Memo. 2000-333.  Therefore, it is               
         more advantageous for petitioner to claim the standard deduction             
         as allowed by respondent in the notice of deficiency.                        
         respondent’s determination is sustained.                                     
              C. Schedule C Deductions                                                
                   1. Sections 162 and 274                                            
              Section 162(a) permits a deduction for the ordinary and                 
         necessary expenses paid or incurred during the taxable year in               






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