Robert A. White - Page 18

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          the $1,965 deduction for cleaning expenses and did not offer any            
          receipts to substantiate any cleaning expenses.                             
               Where business clothes are suitable for general wear, their            
          cost is generally not deductible.  However, where custom and                
          usage forbid wearing a uniform when off duty, deduction is                  
          allowed.  The cost of maintaining clothes for work is deductible            
          when the purchase price was deductible.  Hynes v. Commissioner,             
          74 T.C. 1266, 1290 (1980).                                                  
               We accept petitioner’s testimony that professional cleaning            
          was at times necessary for his uniforms, and we find that it                
          would have been improper for petitioner to wear either his DHS              
          uniform or his military uniform when off duty.  We conclude that            
          petitioner is entitled to a deduction for uniform cleaning in the           
          amount of $480 for 2003.9                                                   
               Petitioner claimed a $225 deduction for expenses relating to           
          work shoes.  Petitioner testified that he had an allowance for              
          shoes but would occasionally have his shoes repaired and that he            
          spent $225 in 2003 on shoe repair.  Petitioner estimated that               
          each heel repair cost $25 to $40 but did not offer any receipts             
          or any details of how often such repairs were necessary.                    

               9 When estimating the taxpayer’s expenses, the Court’s                 
          findings bear heavily against the taxpayer whose inexactitude is            
          of his own making.  Cohan v. Commissioner, 39 F.2d 540, 544 (2d             
          Cir. 1930).  We allow 15 cleanings of his military uniform at $12           
          each and 50 cleanings of his DHS uniform at $6 each.                        

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