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these items were contained in a “bag of receipts” mistakenly
thrown out in the trash by his mother, the elder Mrs. Nwankwo,
sometime in late 2003 when she was staying at petitioners’ home.
Petitioners did not recall a total dollar amount for the receipts
contained in the bag, nor did they testify that the receipts in
question were no longer available. Petitioners produced at trial
photocopies of approximately 15 readable receipts that they
claimed were reflective of the receipts contained in the bag that
was thrown out in the trash. These receipts were received into
evidence.
Again, we cannot tell from the record whether any of the
photocopied receipts provided by petitioners were a part of the
amounts disallowed by respondent. We must therefore sustain
respondent on this issue.
With respect to the disallowed deductions for uniforms and
dry cleaning expenses, we again find that there is nothing in the
record to prove that the “jeans uniform” worn by Mr. Nwankwo in
2003 was required in petitioner’s business, was not suitable
for general or personal wear, and was not worn for general or
personal purposes. Moreover, as a general observations, we are
unwilling to believe that blue jeans of the type Mr. Nwankwo
testified that he wore while on the job required dry cleaning.
Accordingly, we sustain respondent with respect to this
deduction.
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