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goods sold computation. We have no idea what other items
petitioners included in "purchases" or in "materials and
supplies."
But for the reference to $124 in book sales income in
petitioners' records and petitioner's vague testimony on the
point, there is no other evidence of any book sales during 1992.
As for the educational seminars activity, we fail to see how any
of the expenditures that petitioner might have incurred in
connection with such activity would properly be included in a
cost of goods sold computation. See sec. 1.61-3(a), Income Tax
Regs.; see also Hahn v. Commissioner, supra. Conceivably, with
respect to the educational seminar business, some of the
expenditures that petitioner might have included in cost of goods
sold might have been properly deductible under section 162;
however, petitioners have made no such claim, and there is
insufficient information in the record to allow us to make such a
determination on our own. Consequently, respondent's adjustment
reducing the cost of goods sold reported on the Schedule C is
sustained.
II. Schedule C Deductions
In general, section 162 allows deductions for ordinary and
necessary expenses of carrying on a trade or business. Sec.
162(a). As used in section 162(a), "ordinary" has been defined
as that which is "normal, usual, or customary" in the taxpayer's
trade or business. Deputy v. DuPont, 308 U.S. 488, 495 (1940).
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