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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:
Amount
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