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In 1992, petitioner purchased a book on Federal taxation
from Prentice Hall for $142 and deducted this expense on the
return. Petitioner reviewed the book, which covers deductions
and exemptions.
OPINION
Section 162(a) allows a deduction for all ordinary and
necessary expenses incurred in carrying on a trade or business.
The performance of services as an employee constitutes a trade or
business. O'Malley v. Commissioner, 91 T.C. 352, 363-364 (1988).
An ordinary expense is one that is common and acceptable in the
particular business. Welch v. Helvering, 290 U.S. 111, 113-114
(1933). A necessary expense is an expense that is appropriate
and helpful in carrying on the trade or business. Heineman v.
Commissioner, 82 T.C. 538, 543 (1984). An employee's trade or
business is earning his compensation, and generally only those
expenses that are related to the continuation of his employment
are deductible. Noland v. Commissioner, 269 F.2d 108, 111 (4th
Cir. 1959), affg. T.C. Memo. 1958-60. Deductions are a matter of
legislative grace, and petitioner bears the burden of proving
that he is entitled to the deductions claimed. Rule 142(a);
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).
Reimbursable Expenses
When an employee has a right to reimbursement for
expenditures related to his status as an employee, but fails to
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