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cleaning costs resulted from his work uniform, and although he
did not wear a corporate uniform per se, he did wear “jeans from
head to toe.” Articles of clothing are deductible under section
162(a) only if the clothing is required in the taxpayer’s
business, is not suitable for general or personal wear, and is
not worn for general or personal purposes. Yeomans v.
Commissioner, 30 T.C. 757, 767-768 (1958). There is nothing in
the record to prove that the jeans worn by Mr. Nwankwo were
required in petitioner’s business, were not suitable
for general or personal wear, and were not worn for general or
personal purposes. Accordingly, we must sustain respondent with
respect to these expenses.
With respect to the disallowed deductions for telephone
expenses, as a general rule, the deductibility of telephone
expenses is also guided by section 162(a). But see sec. 262(b).
However, if the telephone expense at issue is for a cellular
phone, the stringent substantiation requirements under section
274(d) will apply, as a cellular phone is listed property
pursuant to sections 274(d)(4) and 280F(d)(4)(A)(iv).
The record is devoid of any evidence showing Mr. Nwankwo’s
business-related telephone expenses, or in what amount these
expenses occurred. The only reference contained in the record is
a letter addressed to Mr. Nwankwo from his cellular phone company
notifying him of a replacement fee that he must pay for a non-
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