Michael S. Palmer - Page 6

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          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.                 








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