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ordinary clothing, and the uniforms are not worn as ordinary
clothing. Yeomans v. Commissioner, 30 T.C. 757, 767-769 (1958);
Beckey v. Commissioner, T.C. Memo. 1994-514.
Petitioners introduced the portion of the NWA Flight
Attendant agreement requiring Mrs. Soholt to wear a uniform.
Mrs. Soholt worked 15 to 20 days per month for the 7 months that
she was not on sporadic leave. Mrs. Soholt testified that she
did not dry clean her uniform each time she wore it and that she
often had to clean it herself due to the short time between
trips. Petitioners also introduced receipts from dry cleaners
amounting to $122.59 in cleaning costs for the year, although the
receipts do not specifically indicate that the cleaning charges
were for Mrs. Soholt’s uniforms.
We are convinced that Mrs. Soholt incurred some expenses
during the year to clean her uniforms. We may estimate the
amount of uniform expenses under the Cohan rule. We estimate
that Mrs. Soholt dry cleaned her uniform once per month for the 7
months she worked at NWA and is therefore entitled to deduct $105
for uniform expenses during 2003.
Expenses Subject to Strict Substantiation Requirements
We now consider those expenses that are subject to the
additional strict substantiation requirements under section
274(d). Strict substantiation requires the taxpayer to generally
introduce records or evidence showing the amount of the expense,
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