It dealt with the issue of whether clothes purchased solely for use at work could be treated as a business expense deduction on a taxpayer's return.

She spent $1,381.91 on YSL clothing (at a discount) to meet these requirements, and subsequently deducted that amount from her 1975 federal income tax return as an ordinary and necessary business expense.

Moreover, a subjective test would involve an examination of a taxpayer's personal taste and fashion sense, providing no guidelines for a court to follow in its determination of what is deductible.

Specifically, § 162(a) states that "there shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business….

This section holds that "[e]xcept as otherwise expressly provided in this chapter, no deduction shall be allowed for personal, living, or family expenses.

Courts will find that the suit is generally suitable for ordinary wear, regardless of the particular lawyer's personal dress habits outside of work.

Commissioner's goal was probably to avoid the need to make case-by-case determination based on presence or absence of "convenience of the employer" argument.