Sean M. and Julie M. Riley - Page 16




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          dry cycle and drycleaned his uniform jacket six times per month             
          at $6 per drycleaning.                                                      
               We may estimate the amount of these expenses under the Cohan           
          rule.  We adopt the unit cost of $1.50 listed on petitioners’               
          exhibit as the cost to wash or dry one load of laundry.  We find            
          that approximately eight loads of laundry for each of the months            
          Mr. Riley worked is a reasonable number to yield 22 clean shirts            
          and pants and a jacket per month.  Petitioners are therefore                
          entitled to deduct $288 of uniform cleaning expenses during 2003.           
          Depreciation Expenses                                                       
               Petitioners deducted $296 for depreciation of the tools Mr.            
          Riley used at his job at NWA.  The cost of tools with useful                
          lives greater than a year is 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.  Mr. Riley            
          testified that he acquired his tools on January 1, 2001.                    
               Mr. Riley admitted he had no receipts and that the $2,000              
          reported was his estimate of the replacement costs.  The only               
          documentary evidence petitioners introduced to support their                
          claimed deduction were two lists of minimum tools for mechanics             
          required by NWA.  Petitioners failed to introduce any documentary           
          evidence to show their purchase price or the purchase date.  Mr.            
          Riley also did not describe what specific tools he depreciated              
          nor the tools’ expected useful lives.                                       







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