Thomas D. Stricker - Page 8

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               Petitioner asserts that the cost of the Big League Sales               
          Course and associated expenditures were deductible as ordinary              
          and necessary business expenses pursuant to section 162.                    
          Respondent contends that the course cost and the associated                 
          expenses were personal expenses and not ordinary and necessary              
          business expenses and, therefore, were not deductible pursuant to           
          section 262.                                                                
               Section 162 allows a deduction for "all the ordinary and               
          necessary expenses paid or incurred during the taxable year in              
          carrying on any trade or business".  Certain expenditures made by           
          an individual for education are deductible as ordinary and                  
          necessary business expenses if the expenditure:                             
                    (1) Maintains or improves skills required by the                  
               individual in his employment or other trade or                         
               business, or                                                           
                    (2) Meets the express requirements of the                         
               individual's employer, or other requirements of                        
               applicable law or regulations, imposed as a condition                  
               to the retention by the individual of an established                   
               employment relationship, status, or rate of                            
               compensation.  [Sec. 1.162-5(a), Income Tax Regs.]                     
          Petitioner's participation in a sales course may have maintained            
          or improved the skills required of him in his occupation as a               
          salesman.  The expenditure for such coursework, however, must               
          still be ordinary and necessary in order to be deductible.  Sec.            
          162(a).                                                                     
               "Ordinary" has been defined as that which is "normal, usual,           
          or customary" in the taxpayer's particular trade or business.               





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