E.W. Richardson - Page 40

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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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