Leonard Stockwell - Page 14




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          are of a type specifically required as a condition of employment,           
          the uniforms are not adaptable to general use as 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.                                          
               We are satisfied that petitioner incurred deductible                   
          expenses for uniform cleaning.  Petitioner gave unclear                     
          testimony, however, regarding how he calculated the $722 for                
          cleaning costs.  Petitioner introduced a document on the                    
          letterhead of his CPA that also purports to indicate how the sum            
          was calculated, but it suggests an excessive amount, 22 loads of            
          laundry per month, which was the number of days he estimated he             
          worked each month.                                                          
               We may estimate the amount of deductible cleaning expenses             
          under the Cohan rule.  Petitioner testified that he paid                    
          approximately $1.50 per load of laundry.  We find that petitioner           
          did approximately eight loads of laundry per month at $1.50 for             
          each wash cycle and for each dry cycle.  Petitioner is therefore            
          entitled to deduct $288 of uniform cleaning expenses in 2003.               
          Depreciation Expenses                                                       
               Petitioner deducted $1,842 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                







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