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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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Last modified: May 25, 2011