- 209 - 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 expensesPage: Previous 199 200 201 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 Next
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