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
Last modified: May 25, 2011