Jim Wood Land Clearing Co., Inc. - Page 4

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          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             
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                             under Rule 155.                          

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