- 5 -
Essentially, petitioners make the same arguments here as they did
before the Board.
Discussion
Section 162(a) provides deductions for "all the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on any trade or business". On the other hand, section
262(a) provides that "no deduction shall be allowed for personal,
living, or family expenses." To some extent, there is a
connection between an individual's personal expenses and his or
her business expenses. Thus, for example, while routine meals
are necessary for an individual to function in the workplace, the
expenditure is inherently personal and not deductible under
section 162(a). To establish the deductibility of an expense
under section 162(a), the individual must show more than a
tangential connection with the business: he or she must show
that the questioned expense is "directly connected" with a trade
or business. Sec. 1.162-1(a), Income Tax Regs. We look,
therefore, to the "origin and character" of the expenses to
determine whether they are deductible under section 162(a). Fogg
v. Commissioner, 89 T.C. 310, 315-316 (1987); see also United
States v. Gilmore, 372 U.S. 39, 49 (1963). Furthermore,
petitioners bear the burden of proof. Rule 142(a); INDOPCO, Inc.
v. Commissioner, 503 U.S. 79, 84 (1992). With these principles
in mind, we turn to the disallowed expenses.
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