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arising from petitioner's writing activities. An ordinary and
necessary expense is one which is appropriate and helpful to the
taxpayer's business and which results from an activity which is
common and accepted practice. Boser v. Commissioner, 77 T.C.
1124, 1132 (1981), affd. without published opinion (9th Cir.
1983). Where taxpayers establish that they have incurred trade
or business expenses, but are unable to substantiate the precise
amount of the expenses, we may estimate the amount of the
deductible expenses. Cohan v. Commissioner, 39 F.2d 540, 543-544
(2d Cir. 1930). However, we cannot estimate deductible expenses
unless the taxpayer presents evidence sufficient to provide some
rational basis upon which estimates may be made. Vanicek v.
Commissioner, 85 T.C. 731, 743 (1985).
Section 262 denies a deduction for any personal, living, or
family expenses. The distinction between deductible trade or
business expenses on the one hand, and nondeductible personal
expenses on the other, is based on a weighing and balancing of
the facts and circumstances of each case. R.R. Hensler, Inc. v.
Commissioner, 73 T.C. 168, 176-177 (1979). With respect to
deductions under section 162, the taxpayer bears the burden of
proving that an expense was incurred for business, rather than
personal reasons. Walliser v. Commissioner, 72 T.C. 433, 437
(1979). Specifically, taxpayers must show that the expense was
incurred primarily to benefit their business, and there must have
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