- 8 -
State exam $185
School course 250
Cellular phone &
beeper 1,200
Clothes & cleaning 1,440
Shoes 150
Insurance 20
Supra key pad &
lock box 120
Electronic organizer 300
Miscellaneous 100
In the notice of deficiency, respondent disallowed $3,058 of
the total amount, allowing petitioners a $707 deduction for the
above expenses. Respondent did not identify which of the above
items were allowed, and, based on the record, we were not able to
ascertain the combination of the above items that totals $707.
Nevertheless, ignoring the mathematics and keeping in mind
that petitioners failed to substantiate any of the expenses, we
note the following with regard to some of the larger expense
items listed above. The expenses for clothes, cleaning, and
shoes would not be deductible even if paid and substantiated.
Petitioner’s testimony establishes that the clothing to which the
expenses relate is suitable for general usage. Consequently, the
expenses are personal in nature and may not be deducted. Sec.
262(a); Hynes v. Commissioner, 74 T.C. 1266, 1290 (1980); Foster
v. Commissioner, T.C. Memo. 1990-427. We think it highly
unlikely that any of the $707 allowed by respondent is
attributable to a portion of the deductions for clothes,
cleaning, and shoes.
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Last modified: May 25, 2011