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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 never
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