- 4 -
if it is appropriate or helpful for the business, see Welch v.
Helvering, 290 U.S. 111, 113 (1933). It is not customary or
usual for land clearing businesses to advertise their services by
constructing houses. In addition, payment of the construction
expenses was not appropriate or helpful in promoting petitioner's
land clearing business. Moreover, the expenses were incurred for
Allen Wood's personal benefit, rather than for business
considerations relating to petitioner. See International
Artists, Ltd. v. Commissioner, 55 T.C. 94, 104 (1970) (holding
that a business expense deduction will not be allowed for an
expenditure that is primarily motivated by personal, rather than
business, considerations).
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4
Last modified: May 25, 2011