- 60 -
Even under a subjective methodology, the evidence in the
record is simply insufficient to permit a deduction. Assuming
arguendo that a once-wear policy would render clothing unsuitable
for personal wear in petitioners’ particular situation, Mr.
Deihl’s generalized testimony does little to show that each of
the claimed charges was in fact for the purchase of such a once-
wear item. As respondent notes, among the Neiman Marcus charges
is one showing two turtlenecks at $165 each. We are unconvinced
that Mr. Deihl’s testimony is not overly broad and exaggerated,
and we are left with no reasonable basis on which to make any
estimate as to legitimately once-wear garments.12
I. Equipment and Furnishings
The credit card statements submitted in conjunction with
expenditures claimed under training, meetings, and/or conventions
and under promotion also reflect purchases at various
establishments labeled with descriptions indicating some form of
equipment, furnishings, or similar items. For instance,
petitioners seek to deduct charges to Circuit City and Best Buy
characterized as “ELECTRONICS/APPLIANCES”. Petitioners’
12 As a final observation, we note that an additional basis
for disallowance rests in the fact that Mr. Deihl indicated that
garments were given to charity, thereby raising the possibility
of a double deduction absent evidence that these amounts were not
already incorporated in the charitable contribution deductions
claimed by the various related entities.
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