Bruce K. Remy and Gail E. Remy - Page 8

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             accountants, or other tax professionals, he did                          
             “informally” seek the advice of professionals with whom he               
             was acquainted.                                                          
                                       OPINION                                        
             Advertising Expenses                                                     
                  The principal issue in this case is whether                         
             petitioners are entitled to deduct, as an advertising                    
             expense under section 162, the value of the uncompensated                
             medical services Dr. Remy provided to his patients during                
             the years in issue.  Section 162 allows an individual to                 
             deduct all ordinary and necessary expenses paid or incurred              
             during the taxable year in carrying on a trade or business.              
             Sec. 162(a).  Respondent does not question petitioners'                  
             method of valuing Dr. Remy's telephone services, and does                
             not seriously question the relationship of those services                
             to Dr. Remy's trade or business.  Respondent asserts that                
             the deductions are not allowable because the amounts that                
             petitioners seek to deduct are not expenditures that                     
             petitioners, cash basis taxpayers, "paid" during any of the              
             years in issue, as required by section 162(a).  We agree                 
             with respondent.                                                         
                  We start with the principle that deductions are a                   
             matter of legislative grace and are to be narrowly                       
             construed.  See, e.g., Commissioner v. Jacobson, 336 U.S.                






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