6 Income Tax Regs. We sustain respondent's determination of petitioner's income for 1992 and 1993. C. Deductions 1. Background A taxpayer may deduct ordinary and necessary business expenses. Sec. 162. To qualify for a business deduction, a taxpayer must show that he or she paid or incurred the expense in carrying on a trade or business in the taxable year and that the expense was ordinary and necessary. Commissioner v. Lincoln Sav. & Loan Association, 403 U.S. 345, 352 (1971). Respondent determined that petitioner had deductible business expenses under section 162 equal to 15 percent of his compensation; i.e., $17,924 for 1992 and $16,004 for 1993. To be entitled to deduct more than respondent concedes, petitioner must show that he had more business expenses than those amounts. Petitioner contends that he may deduct amounts he paid to others. As discussed at paragraph B, above, petitioner did not convince us that he paid any amounts to others in the years in issue. 2. Worker's Compensation Expense Petitioner contends that he may deduct 12 percent of the total amount that he claimed in the invoices he submitted to MAP for worker's compensation insurance premiums. We disagree.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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