- 6 - and other general “business attire” which petitioner typically wore only to work. The clothing expenses incurred by petitioner were for clothes of a type which can be worn outside of work. A deduction may not be claimed for such expenses because they are nondeductible personal expenses rather than business expenses, even if the clothing was in fact used exclusively for work. Sec. 262(a); Barone v. Commissioner, 85 T.C. 462, 469 (1985) (“The general rule concerning the deductibility of work clothes under section 162(a) is that they must be of a type specifically required as a condition of employment and not adaptable to general usage as ordinary clothing.”), affd. without published opinion 807 F.2d 177 (9th Cir. 1986). Petitioner has failed to substantiate the bulk of the employee business expenses for which he claimed a deduction. Although petitioner provided an estimate for two of the remaining items, these items total only $220 to $240 and do not meet the 2-percent floor imposed by section 67(a). We therefore sustain respondent’s disallowance of the employee business expense deduction. Secs. 67(a), 6001; sec. 1.6001-1(a), (e), Income Tax Regs. The second issue for decision is whether petitioner received unreported interest income. Respondent determined that petitioner received interest income of $13 from the Internal Revenue Service during 1999. Petitioner argues that he neverPage: Previous 1 2 3 4 5 6 7 8 Next
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