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that a deduction will be allowable only if it is “ordinary and
necessary”. An “ordinary” expense is one that is normal or
common in the particular trade or business. Palo Alto Town &
Country Village, Inc. v. Commissioner, 565 F.2d 1388, 1390 (9th
Cir. 1977), remanding T.C. Memo. 1973-223; Noyce v.
Commissioner, 97 T.C. 670, 685 (1991). “An expense is necessary
if it is appropriate and helpful in carrying on the trade or
business.” Noyce v. Commissioner, supra at 685; see also Palo
Alto Town & Country Village, Inc. v. Commissioner, supra at 1390.
Finally, for an expense to be considered ordinary and necessary,
it must also be reasonable in amount in relation to its purpose.
Noyce v. Commissioner, supra at 687; Sherman v. Commissioner,
T.C. Memo. 1982-582; Harbor Medical Corp. v. Commissioner, T.C.
Memo. 1979-291, affd. without published opinion 676 F.2d 710 (9th
Cir. 1982). We examine the facts and circumstances of the
particular case to determine whether an expense is ordinary and
necessary. Palo Alto Town & Country Village, Inc. v.
Commissioner, supra at 1390; Noyce v. Commissioner, supra at 686-
688.
Respondent first argues that the airplane expenditures were
incurred primarily for the personal benefit of petitioner.
Respondent does not premise this argument on petitioner’s
concededly personal use of the airplane, which accounted for 3
percent and 9 percent of the total use of the airplane for 1988
and 1989, as petitioner paid the actual cost associated with such
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