Samuel C. Stone and Susan C. Stone - Page 10

                                       - 10 -                                         
          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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