Lucy M. Wiggins - Page 14




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          to purchase and clean uniforms, shoes, hats, and a raincoat for             
          work.  Petitioner did not provide any evidence concerning either            
          the cost of each item of clothing she purchased or the cost to              
          clean the items.  Further, the purchase of the uniform was not a            
          necessary expense under section 162(a) because petitioner                   
          voluntarily purchased the uniform instead of wearing the uniform            
          provided by her employer.  We conclude that petitioner is not               
          entitled to a deduction for the claimed expenses for work                   
          clothing or for the care of the work clothes, and respondent’s              
          determination is sustained.                                                 
               5.   Tax Preparation Fees                                              
               A taxpayer may be allowed a deduction for ordinary and                 
          necessary expenses paid or incurred during the taxable year in              
          connection with the determination, collection, or refund of any             
          tax.  Sec. 212(3).                                                          
               Petitioner presented no evidence to support the claimed                
          deduction for tax preparation fees.  We conclude that petitioner            
          is not entitled to the claimed deduction for tax preparation                
          fees, and respondent’s determination is sustained.                          
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               






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