-52- "Necessary" has been construed to mean "appropriate" or "helpful", not "indispensable" or "required". Ford v. Commissioner, 56 T.C. 1300, 1306 (1971), affd. 487 F.2d 1025 (9th Cir. 1973). It is sufficient if "there are also reasonably evident business ends to be served, and the intention to serve them appears adequately from the record." B. Manischewitz Co. v. Commissioner, 10 T.C. 1139, 1145 (1948). The substantiated expenses were also necessary, in that they were incurred with the intention of serving the business end, mainly the conduct of a business school in Russia. Petitioners are entitled to deduct $20,033 as ordinary and necessary expenses of the business school on their 1991 Schedule C. Unreported Income--Chorny Respondent determined that petitioners failed to report Schedule C income of $20,472 and $9,250 in 1990 and 1991, respectively. At trial, petitioner testified that the payments received from Chorny represented loan repayments. As evidence of the debt, petitioners offered reproductions of checks payable to Chorny or Margarita Chorny. We are not persuaded by the checks payable to the Chornys that Chorny was indebted to petitioner or that the checks petitioner received during 1990 and 1991 from Chorny were not includable in petitioners' income. At the trial of this case,Page: Previous 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 Next
Last modified: May 25, 2011