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Employee Business Expense Deductions
During 1991 petitioner paid the following expenses in
connection with his employment with Stone Jessup:
Vehicle $2,673.06
Parking fees, tolls, other trans. 270.80
Travel 1,242.21
Meals and entertainment 2,603.23
Workshops, forums 90.86
Petitioners argue that the expenses are deductible as employee
business expenses pursuant to section 162(a).
In general, a taxpayer is entitled to deductions pursuant to
section 162(a) for all ordinary and necessary expenses paid or
incurred during the taxable year in carrying on a trade or
business. The term "trade or business" as used in section 162(a)
includes the trade or business of being an employee. Primuth v.
Commissioner, 54 T.C. 374, 377 (1970); Christensen v.
Commissioner, 17 T.C. 1456 (1952); Abraham v. Commissioner,
9 T.C. 222 (1947). An expense is ordinary if it is considered to
be "normal, usual, or customary" in the context of the particular
business out of which it arose. Deputy v. du Pont, 308 U.S. 488,
495 (1940). An expense is necessary if it is appropriate and
helpful to the operation of the taxpayer's trade or business.
Commissioner v. Tellier, 383 U.S. 687, 689 (1966); Carbine v.
Commissioner, 83 T.C. 356, 363 (1984), affd. 777 F.2d 662 (11th
Cir. 1985). Corporate officers, employees, and shareholders who
voluntarily incur corporate expenses are generally not entitled
to deductions for these expenditures because such expenditures
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