Robert and Cheryl McKeown - Page 15
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of pants per month. Petitioners are therefore entitled to deduct
$259.20 for cleaning expenses for Mr. McKeown’s uniforms in 2003.
Petitioners deducted $3,031 for depreciation of the tools he
used at his job at NWA. The costs of tools with useful lives
greater than a year are recoverable by depreciation. Secs.
167(a), 168(b); Seawright v. Commissioner, 117 T.C. 294, 305
(2001); Clemons v. Commissioner, T.C. Memo. 1979-273.
Petitioners introduced a list and photographs of Mr. McKeown’s
tools as well as a depreciation schedule indicating that he
purchased his tools on January 1, 2003. Petitioners did not
introduce any documentary evidence regarding the tools, however,
such as receipts that would show their purchase price or the
purchase date. Petitioners also did not introduce evidence
supporting the tools’ expected useful lives.
Petitioners have not substantiated that they are entitled to
a depreciation deduction. Further, we are unable to estimate any
amount for depreciation under the Cohan rule because the evidence
petitioners introduced is inadequate. Petitioners are therefore
not entitled to deduct any amount for depreciation.
Cellular Phone Expenses
Petitioners claimed $1,800 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
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Last modified: November 10, 2007