Sandra Pevsner (plaintiff) managed a boutique that sold expensive and fashionable women’s clothing. To help promote sales and the boutique’s image, the owner of the boutique required Pevsner to purchase and wear boutique clothing during work hours or work-related activities. The owner would have allowed Pevsner to wear the wardrobe at home. However, Pevsner believed that the wardrobe was not simple enough for her modest home lifestyle, and wore the wardrobe only for work. Pevsner deducted the costs of buying and maintaining the wardrobe as ordinary and necessary business expenses. The commissioner of internal revenue (commissioner) (defendant) denied the deduction on the grounds that the wardrobe was suitable for Pevsner’s personal use as well as for work. In federal tax court, Pevsner filed a petition challenging the commissioner’s determination. The tax court found for Pevsner. The commissioner appealed.