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amount, time, place, and business purpose of the expense. Sec.
274(d). Even if such an expense would otherwise be deductible,
the deduction may still be denied if there is insufficient
substantiation to support it. Sec. 1.274-5T(a), Temporary Income
Tax Regs., supra.
Petitioners deducted unreimbursed employee business expenses
for protective clothing of $693 and $529 for tax years 1996 and
1997, respectively. Section 162 allows taxpayers to deduct
amounts for work clothing by establishing that the clothing (1)
was required or essential in the taxpayer’s employment, (2) was
not suitable for general or personal wear, and (3) was not so
worn. Yeomans v. Commissioner, 30 T.C. 757, 767 (1958); Kozera
v. Commissioner, T.C. Memo. 1986-604. Petitioner testified that
he purchased leather work clothing, including coveralls, and
leather gloves for protection when welding. He further testified
that these items were often damaged or “burnt up” throughout the
year. We are satisfied that petitioner did incur some expenses
for these items. Cohan v. Commissioner, supra. We find that
petitioner incurred the expenses in the amounts claimed in their
1996 and 1997 income tax returns. Kozera v. Commissioner, supra.
Petitioners deducted lodging expenses of $2,488 and $1,058
for 1996 and 1997, respectively, and a meals and entertainment
expense of $114 for 1996. At trial, petitioner testified that he
kept a diary of lodging expenses for the years in issue; however,
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