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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Last modified: November 10, 2007