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.           
          Depreciation Expenses                                                       
               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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