- 7 - traveled for purposes of her claimed deduction. Given the contradictory nature and general unreliability of petitioner’s testimony and the evidence produced, we find that petitioner has failed to substantiate her 2003 and 2004 vehicle expenses. Next, we must address petitioner’s cleaning expenses. Petitioner provided no receipts to substantiate her cleaning expenses. As we have already established, petitioner’s logs are unreliable and insufficient to substantiate those expenses. Additionally, petitioner failed to show that she was required to wear a uniform to work, thus failing to prove that her cleaning expenses met the ordinary and necessary business requirement under section 162. Accordingly, we sustain respondent’s determination to disallow petitioner’s deduction for her cleaning expenses. We must next address petitioner’s cell phone expenses. As a general rule, section 262 prohibits a deduction for expenses that are personal in nature. The prohibition of section 262 regarding the deductibility of personal expenses takes precedence over the allowance provision of section 162, Sharon v. Commissioner, 66 T.C. 515, 522-525 (1976), affd. 591 F.2d 1273 (9th Cir. 1978), and a taxpayer must demonstrate that the expenses at issue were different from or greater than what he would have spent for personal purposes, Sutter v. Commissioner, 21 T.C. 170, 173-174 (1953).Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007