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to sponsor a club. Respondent further contends that the costs
were not incurred primarily to maintain petitioner's skills
required in his employment or other trade or business. Thus,
respondent argues that the costs were not incurred by petitioner
in carrying on his trade or business and are not allowable. In
the alternative, respondent argues that the costs are non-
deductible capital expenditures subject to depreciation over the
useful life of the comic books and contends that petitioners have
failed to establish the useful life of the comic books.
Section 162 allows a deduction for ordinary and necessary
expenses paid or incurred by a taxpayer in carrying on a trade or
business. The expenses must be directly or proximately related
to the taxpayer's trade or business. Deputy v. du Pont, 308 U.S.
488, 494-495 (1940); sec. 1.162-1, Income Tax Regs. An expense
is considered ordinary if commonly or frequently incurred in the
trade or business of the taxpayer. Deputy v. du Pont, supra at
495-496. A necessary expense is one that is appropriate or
helpful in carrying on petitioner's trade or business.
Commissioner v. Heininger, 320 U.S. 467, 475 (1943). The expense
must also be reasonable in amount relative to its purpose.
Cardwell v. Commissioner, T.C. Memo. 1982-453 (citing United
States v. Haskal Engg. & Supply Co., 380 F.2d 786, 788 (9th Cir.
1967). An employee's trade or business is earning his
compensation, and generally only those expenses that are related
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