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entitled to deduct all of his claimed expenses. Respondent
asserts that we should not estimate petitioner's expenses because
petitioner has not demonstrated that the expenses were incurred
for a business purpose. Respondent argues that petitioner is not
entitled to all claimed Schedule C expenses because he has not
properly substantiated such expenses in accordance with sections
162, 179, 274(d), and 280F(d).
Section 162(a) provides "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." The regulations promulgated under section 162 provide
that only those expenses "directly connected with or pertaining
to the taxpayer's trade or business" may be deducted. Sec.
1.162-1(a), Income Tax Regs.
Whether an expenditure is ordinary and necessary is
generally a question of fact. To be "necessary" an expense need
be "appropriate and helpful" to the taxpayer's business. Welch
v. Helvering, 290 U.S. 111, 113 (1933). For an expense to be
"ordinary", "the transaction which gives rise to it must be of
common or frequent occurrence in the type of business involved".
Deputy v. duPont, 308 U.S. 488, 495 (1940) (citing Welch v.
Helvering, supra at 114). The taxpayer bears the burden of
proving that the claimed expense is deductible. Welch v.
Helvering, supra at 115.
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