Jordon Jay Fingar - Page 11

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               A.  Automobile Expenses                                                
               Respondent determined that petitioner may deduct $530 in               
          automobile expenses for 1979 and $0 for 1980.  Petitioner asserts           
          that he used his Jaguar XJ-12-L (the car) solely for business               
          purposes; therefore his deductions for the taxable years in issue           
          are fully allowable.                                                        
               Section 162 generally allows a taxpayer to deduct all                  
          ordinary and necessary expenses incurred during the taxable year            
          in carrying on a trade or business.  Sec. 162(a).  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, 495-496 (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).  A taxpayer's general statement that his              
          expenses were incurred in pursuit of a trade or business normally           
          is not sufficient to establish that the expenses had a reasonably           
          direct relationship to that trade or business.  Ferrer v.                   
          Commissioner, 50 T.C. 177, 185 (1968), affd. per curiam 409 F.2d            
          1359 (2d Cir. 1969).  Rather, a taxpayer ordinarily must maintain           
          records sufficient to permit verification of income and expenses.           




          6(...continued)                                                             
          Auto      $530                -0-                                           
          T&E       1,136                 $1,950                                      
          Sailboat       -0-                 -0-                                      



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