Christopher D. and Kristie M. Farran - Page 15

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          business portion of utility expenses under the Cohan rule.  See             
          Pistoresi v. Commissioner, T.C. Memo. 1999-39.                              
               The parties stipulated that petitioners paid $219.50 for               
          Microsoft Online Service in 2003.  Mr. Farran testified that he             
          used the Internet during 2003 to search for a new job while he              
          was unemployed and also to monitor his investments.  Mr. Farran             
          also testified that Mrs. Farran and their children did not use              
          the Internet and he did not use it for other personal purposes.             
               We found Mr. Farran’s testimony on this issue credible, and            
          we are convinced that a portion of Mr. Farran’s Internet use                
          during the time he was unemployed was to search for a job in his            
          field.  We are permitted to estimate the portion of this expense            
          attributable to job searching under the Cohan rule.  We estimate            
          that 50 percent of Mr. Farran’s Internet use during the 7 months            
          he was unemployed in 2003 was to search for a job.  Accordingly,            
          we conclude that petitioners are entitled to deduct $64 of                  
          Internet access charges as job search expenses for 2003.                    
          Cleaning Expenses for Uniforms                                              
               Petitioners claimed $722 for cleaning expenses for Mr.                 
          Farran’s NWA uniforms.  Expenses for uniforms are deductible if             
          the uniforms are of a type specifically required as a condition             
          of employment, the uniforms are not adaptable to general use as             
          ordinary clothing, and the uniforms are not worn as ordinary                

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