Bruce K. Remy and Gail E. Remy - Page 13

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             perceive that, in rendering professional services, Dr. Remy              
             has not "paid" an expense for purposes of section 162.  As               
             we noted in Rink v. Commissioner, supra at 753:                          

                  Just as "imputed income" arising from the bene-                     
                  fit a taxpayer's own services yield to him is                       
                  not taxable under our system of taxation,                           
                  neither is the "imputed expense" arising out                        
                  of his exertions a proper deduction from income.                    
                  Labor performed by a taxpayer does not constitute                   
                  an amount "paid or incurred" by him, and conse-                     
                  quently, cannot be deducted by him under section                    
                  162 * * *.  [Citations omitted.]                                    

             None of the cases cited by petitioners holds to the                      
             contrary.  In two of the cases, the expenditures that were               
             held to qualify as business expenses under section 162                   
             consisted of cash or property and did not involve unpaid                 
             services provided by the taxpayer.  In Wright v. Commis-                 
             sioner, supra the taxpayer was permitted to deduct the                   
             value of "trade units" that he had repaid to the exchange.               
             In Sullivan v. Commissioner, supra the taxpayer was                      
             permitted to deduct the cost of the beer he gave to his                  
             customers.  In the instant case, on the other hand,                      
             petitioner made no expenditure of cash or property and,                  
             thus, no expenditure for which a business deduction is                   
             allowable under section 162.                                             
                  The third case cited by petitioners, Newark Morning                 
             Ledger Co. v. United States, supra, does not involve a                   






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