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The second issue relates to several expenses petitioner
claimed in the various activities in which she was engaged,
described earlier.
Section 162(a) allows a deduction for "all the ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on any trade or business". Sec. 162(a). An expense
must be both ordinary and necessary within the meaning of section
162(a). See Deputy v. duPont, 308 U.S. 488, 495 (1940). Whether
an amount in question constitutes an ordinary and necessary
expense incurred in the operation of the taxpayer's trade or
business is a question of fact to be determined from the evidence
presented. See Welch v. Helvering, 290 U.S. 111 (1933); Allen v.
Commissioner, T.C. Memo. 1988-166.
The first expense item is $948, which petitioner claims she
is entitled to deduct as expenses incurred in connection with her
Klyce Day Care activity during 1990.
In substantiation of this item, petitioner presented
photocopies of the following 10 canceled checks, which bore an
imprinted address of "Klyce Day Care, 1828 Rosedale Ave.,
Oakland, CA 94601":
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