- 13 - 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 aPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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