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5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6,
1985).
Petitioner testified that his remodeling work required him
to "spend a lot more time driving around getting specific items
for a specific job, specialty items." Petitioner also testified
that his method of recording his business miles was to write down
the mileage for his truck at the beginning of the year and to
note the mileage at the end of the year.
Petitioner testified that he bought a computer in 1999 that
he used for both business and personal purposes in 2000.
Petitioner claims that he is entitled to deduct the part of the
cost of the computer that he paid in 2000 as a business expense.
The Court finds that petitioner has failed to meet the
adequate records requirements of section 274 with respect to his
truck and his computer.
Deduction of Expenses for Work Clothing
Petitioner claims that he is entitled to a deduction for
"work clothing", including winter boots, pants, underwear, and a
liner. Expenses for work clothing may be deductible under section
162 if the taxpayer can establish that: (1) The clothing was
required or essential in the taxpayer's employment; (2) the
clothing was not suitable for general or personal wear; and (3)
the clothing was not so worn. Yeomans v. Commissioner, 30 T.C.
757, 767-769 (1958); Kozera v. Commissioner, T.C. Memo. 1986-604.
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