-51- Business School Petitioners claimed $28,417 of expenses related to the business school on their 1991 Schedule C. Respondent disallowed all of the claimed deductions. We found as a fact that petitioners paid at least $20,033 of expenses associated with the AESI contract, including $9,240 to AESI and $10,793 for gasoline, travel, lodging, meals, and entertainment. Petitioners have failed to substantiate any additional expenses. We must thus determine whether the substantiated expenses are ordinary and necessary and, therefore, deductible. Section 162(a) allows a deduction for "all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business". "Ordinary" has been defined as that which is "normal, usual, or customary" in the taxpayer's particular trade or business. Deputy v. du Pont, 308 U.S. 488, 495 (1940). The expense need not be one common for the particular taxpayer, but instead one that is not rare in the taxpayer's business. See Welch v. Helvering, 290 U.S. 111, 114 (1933). The substantiated expenses included "normal" expenses for the conduct of a business school abroad, including travel to and from Russia for petitioner and the faculty; the expenses for AESI's building the curriculum and locating the faculty; the food, meals, and lodging for the faculty in Russia; and the travel, food, meals, and lodging for the top students from Russia who came to the United States after the school.Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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