Marcus Wayne and Judity Caroline Ramsey - Page 14

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          1976); sec. 1.6001-1(a), Income Tax Regs.   If claimed deductions           
          are not adequately substantiated, we may estimate them, provided we         
          are convinced that the taxpayer has incurred such expenses and we           
          have a basis upon which to make an estimate.  Cohan v.                      
          Commissioner, 39 F.2d 540 (2d Cir. 1930); Vanicek v. Commissioner,          
          85 T.C. 731, 743 (1985).                                                    
                Pursuant to section 162(a), a taxpayer may deduct all                 
          ordinary and necessary expenses paid or incurred during the taxable         
          year in carrying on a trade or business.  In general, an expense is         
          ordinary if it is considered “normal, usual, or customary” in the           
          context of the particular business out of which it arose.  Deputy           
          v. duPont, 308 U.S. 488, 495-496 (1940).  The term “ordinary” is            
          also used to distinguish currently deductible items from capital            
          expenditures.  Commissioner v. Tellier, 383 U.S. 687, 689-690               
          (1966).  An expense is necessary if it is appropriate and helpful           
          to the operation of the taxpayer’s trade or business.  Carbine v.           
          Commissioner, 83 T.C. 356, 363 (1984), affd. 777 F.2d 662 (11th             
          Cir. 1985); Heineman v. Commissioner, 82 T.C. 538, 543 (1984).              
          Only the portion of an expense that is reasonable in amount is              
          deductible under section 162.  United States v. Haskel Engineering          
          & Supply Co., 380 F.2d 786, 788-789 (9th Cir. 1967).                        
               Pursuant to section 262(a), personal, living, or family                
          expenses may not be deducted, except as otherwise expressly                 
          provided in the Code.  Furthermore, no deduction is allowed if an           
          employee is reimbursed for his expenses and does not include such           




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