Lawrence K. and Ruth L. Harrell - Page 11

                                       - 10 -                                         
         for the cleaning of his uniforms.  Although petitioners would be             
         entitled to a deduction for the cost of washing and ironing the              
         uniforms, they provided no evidence upon which we can estimate the           
         amount thereof.  At trial, Mrs. Harrell testified that the amount            
         claimed was a guess that was based on the hypothesis of paying to            
         have the uniforms cleaned commercially.  Deductions are based on             
         actual, not hypothetical, costs.                                             
              As the uniforms were not sent to a commercial cleaner but               
         were laundered and ironed at home, the amount claimed is not                 
         allowable.  Moreover, the amount claimed ($468.75 per month)                 
         appears grossly inflated.  In the absence of a rational basis for            
         estimating the cost of the cleaning of the uniforms, we sustain              
         respondent’s disallowance of this component of the claimed                   
         unreimbursed employee and other miscellaneous expenses.  See Cohan           
         v. Commissioner, supra at 543-544.                                           
              Petitioners deducted $3,510 for “supplies and equipment” for            
         the taxable year in issue.  Taxpayers carrying supplies on hand              
         can deduct the costs of those supplies to the extent that the                
         supplies are actually consumed or used in operation during the               
         taxable year for which the return is made if the cost of the                 
         supplies was not deducted in a previous year.  If the supplies are           
         incidental and are carried on hand with no record of consumption             
         kept, the taxpayer may deduct the total cost of such supplies                







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011