Lionel D. Jones - Page 8

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          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 under             





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