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however, regarding how he calculated the $822 for cleaning costs.
Mr. Bogue introduced a document on the letterhead of his CPA that
also purports to indicate how the sum was calculated, but it
suggests an excessive amount, 22 loads of laundry per month,
roughly corresponding to the number of days Mr. Bogue worked each
month.
We may estimate the amount of deductible cleaning expenses
under the Cohan rule. Mr. Bogue testified that he paid $2 to $4
for each cycle and that he did two loads of laundry per week. We
find that Mr. Bogue did approximately eight loads of laundry per
month at $2 for each wash cycle and $2 for each dry cycle.
Petitioners are therefore entitled to deduct $304 of uniform
cleaning expenses in 2003.
Cellular Phone Expenses
Petitioners claimed $240 of cellular phone expenses for
2003. Cellular phones are included in the definition of “listed
property” for purposes of section 274(d)(4) and are thus subject
to the strict substantiation requirements. Sec.
280F(d)(4)(A)(v); Gaylord v. Commissioner, T.C. Memo. 2003-273.
A taxpayer must establish the amount of business use and the
amount of total use for the property to substantiate the amount
of expenses for listed property. Nitschke v. Commissioner, T.C.
Memo. 2000-230; sec. 1.274-5T(b)(6)(i)(B), Temporary Income Tax
Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). Expenses subject to
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