Susan E. Shores - Page 5

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               Petitioner stored her business and tax records in a shed               
          behind the carport at her home.  In the fall of 1995, a                     
          combination of excessive rain and a leak in the carport caused              
          the destruction of petitioner's 1994 tax records and other                  
          personal items in the shed.  After the incident, petitioner                 
          notified her insurance representative and her landlord about the            
          damage.  In January 1997, after the issuance of the notice of               
          deficiency, petitioner began reconstructing her 1994 tax records.           
               Respondent determined that petitioner was not entitled to              
          deduct any of the claimed Schedule C expenses.  Respondent does             
          not dispute that petitioner's records were destroyed because of a           
          casualty beyond petitioner's control.  Further, respondent does             
          not appear to dispute that petitioner reasonably reconstructed              
          her records for 1994.  Rather, respondent contends that                     
          petitioner's expenses were not ordinary and necessary business              
          expenses.                                                                   
          Discussion                                                                  
               1.  General                                                            
               Section 162(a) provides that there shall be allowed as a               
          deduction all the ordinary and necessary expenses paid or                   
          incurred during the taxable year in carrying on any trade or                
          business.  "Necessary" has been interpreted to mean that the                
          expense must be appropriate or helpful to the taxpayer's trade or           
          business.  Commissioner v. Tellier, 383 U.S. 687, 689 (1966);               
          Joseph v. Commissioner, T.C. Memo. 1997-447 (citing Welch v.                




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