- 7 - item. Respondent, therefore, is sustained on the claimed second telephone and cellular telephone expenses. Brodsky v. Commissioner, T.C. Memo. 2001-240. With respect to the uniforms, dry cleaning and laundry, association and professional dues, firing range expenses, ammunition, camera, and gun expenses, the strict substantiation rules do not apply, and the Court is satisfied that petitioner did incur deductible expenses for these items. Although petitioner admitted he was “not the world’s best record-keeper,” he testified credibly with respect to these items and their business purpose. In the absence of adequate substantiation, this Court may, if convinced by the evidence, estimate the amount of deductible expenses incurred. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). Therefore, under the Court's discretionary authority pursuant to Cohan, the following amounts are allowed as unreimbursed employee business expense deductions on Schedule A: Uniforms, $200; dry cleaning and laundering of uniforms, $500; association and professional dues, $500; firing range and ammunition costs, $100; firearm and camera, $200, for a total of $1,500. See McGovern v. Commissioner, 42 T.C. 1148 (1964) (expense for nurse’s uniforms allowed under Cohan rule), affd. 17 AFTR2d 944, 66-1 USTC par. 9455 (6th Cir. 1966); Fisher v. Commissioner, 23 T.C. 218 (1954) (purchase and laundering of formal clothing expenses of professional musician allowed underPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011