Deductibility of Cost of Washing UPS Uniform

The Tax Court yesterday decided Harrell v. Commissioner, T.C. Summ. Op. 2006-165.  The case is otherwise unremarkable except for an interesting discussion of the tax treatment of cleaning a UPS driver's uniform:

Petitioners deducted $5,625 for uniforms for the taxable year and stipulated that the uniforms Mr. Harrell wore were washed and ironed at petitioners’ home.... Mr. Harrell, in his position with United Parcel Service, was required to work in a clean uniform every day. Mrs. Harrell washed and ironed Mr. Harrell’s work uniforms at home. The employer provided the uniforms but did not reimburse Mr. Harrellfor the cleaning of his uniforms. Although petitioners would be entitled to a deduction for the cost of washing and ironing the uniforms, they provided no evidence upon which we can estimate the amount thereof. At trial, Mrs. Harrell testified that the amount claimed was a guess that was based on the hypothesis of paying to have the uniforms cleaned commercially. Deductions are based on actual, not hypothetical, costs.

As the uniforms were not sent to a commercial cleaner but were laundered and ironed at home, the amount claimed is not allowable. Moreover, the amount claimed ($468.75 per month) appears grossly inflated. In the absence of a rational basis for estimating the cost of the cleaning of the uniforms, we sustain respondent’s disallowance of this component of the claimed unreimbursed employee and other miscellaneous expenses.