Trent Deshawn Allston - Page 8

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               At trial, petitioner did not offer any receipts or documents           
          to substantiate his claimed employee business expenses.  Instead,           
          he testified as to his claimed business expenses.  With respect             
          to the uniforms and dry cleaning, equipment, and professional               
          dues, the Court is satisfied that petitioner did incur deductible           
          expenses for these items.  Although petitioner admitted he did              
          not have receipts to substantiate these expenses, he testified              
          credibly with respect to these items and their business purpose.            
          Petitioner did admit, however, that his return preparer                     
          “exceeded” what was actually spent on uniforms, dry cleaning, and           
          equipment during the year at issue.  Accordingly, petitioner                
          conceded that he spent, at most, $4,000 on uniforms and dry                 
          cleaning and $1,200 to $1,500 on equipment in 2002.                         
               In the absence of adequate substantiation, the Court may, if           
          convinced by the evidence, estimate the amount of deductible                
          expenses incurred.  Cohan v. Commissioner, supra at 543-544.                
          Under the Court’s discretionary authority pursuant to Cohan, the            
          following amounts are allowed as unreimbursed employee business             
          expense deductions on Schedule A:                                           
               Uniforms and dry cleaning                         $  500               
               Equipment                                         350                  
               Professional dues                                  500                 
               Total                                             $1,350               
               With regard to the $2,960 in unreimbursed employee business            
          expense for tuition, petitioner testified that his coursework at            

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Last modified: May 25, 2011