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contends that the evidence presented with respect to the business
expense deductions was virtually unchallenged by respondent. It
is our view that, for the most part, there was no need for
respondent to challenge the evidence offered by petitioner on the
deduction issues because the evidence presented failed to show
that the majority of the business expenses claimed were
petitioner's ordinary and necessary business expenses or that he
was otherwise entitled to the various amounts claimed. He also
contends that respondent's reasons for disallowing various
deductions were not clear in every instance. To the contrary,
the notices of deficiency specifically set forth which deductions
were allowed and disallowed, and provide a narrative explanation
for the disallowance.
We have made detailed and specific findings of fact with
respect to the claimed business expense deductions. We think no
useful purpose would be served by reiterating each and every fact
in this opinion. However, we will discuss the major disputed
items.
Section 162(a) provides that "There shall be allowed as a
deduction all the ordinary and necessary expenses paid or
incurred during the taxable year in carrying on any trade or
business". The regulations promulgated under section 162 clarify
that only those ordinary and necessary business expenses
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