Can Nurses Deduct Manicures?

Unfortunately, no. They cannot.

If it were up to me, they definitely could. I'm a big fan of nurses and all medical care professionals. These are good people doing good work for humanity, and they deserve a break. But this IRS won't allow a deduction for manicures on a tax return and they make the rules, not me.

Actually, the US Tax Court makes the rules, or determines them anyway. The court has ruled several times that certain grooming expenses such as haircuts, dry cleaning, makeup, teeth whitening, and nail maintenance costs are considered personal expenses in nearly all cases, even if your employer mandates you to have clean clothes and tightly-cropped nails.

The court's logic is as follows: with respect to clothing, even if a specific "look" or set of attire is a necessary condition of employment, the cost of clothing is considered a nondeductible personal expense (Kennedy v. Commissioner, T.C. Memo. 1970-58). Uniforms are treated differently, but the general rule is that any clothing that can be adapted to normal use (e.g., worn to the club) are not uniforms and are not deductible (yes, this includes polo shirts with a logo, sorry about that) (Donnelly v. Commissioner, 28 T.C. 1278 1957, Hynes v. Commissioner 1980, Roth v. Commissioner, 17 T.C. 1450 1952). Purchases of clothing are not deductible even if the taxpayer would not have purchased them except as a condition of employment (Stiner v. United States, 524 F.2d 640 10th Cir. 1975). Because the cost of clothing items are not deductible, the cost of cleaning the items is also not deductible.

With respect to physical appearance, a case involving a Soldier in the United States Army (Drake v. Commissioner, 52 T.C. 842 1969) shot a hole in any taxpayer claiming "grooming" or personal standard deductions upheld in several cases since, including Hynes. The Court held that an enlisted man in the U.S. Army who was required to have his hair cut every two weeks could not deduct the cost of such haircuts since the expense was personal and hence nondeductible. "The fact that the Army may have required such grooming does not make the expenses therefor any less personal. The evidence showed that the Army's requirement was directed toward the maintenance by the petitioner of a high standard of personal appearance and not toward the accomplishment of the duties of his employment." This standard has been applied to countless less strict employers, including in the entertainment industry and medical field.

Therefore, nurses cannot deduct the cost of manicures, either. It's a bummer.