Don D. Coffman and Debra Coffman - Page 6




                                        - 6 -                                         

          Section 179                                                                 
               Petitioners filed a Schedule C on which they claimed a                 
          section 179 deduction of $7,594.  Petitioners agree that the                
          filing of the Schedule C was erroneous and that the claimed                 
          deduction should have been claimed on Schedule A as an employee             
          business expense of Mr. Coffman’s.  Moreover, the $7,594 is                 
          conceded as an erroneous combination of two computer printouts,             
          one for $3,758 and one for $3,836, pertaining to the same assets.           
          Therefore, the issue is whether petitioners are entitled to a               
          section 179 deduction for $3,758, with regard to petitioners’               
          cost for a computer of $2,134, a printer/fax of $912, and a desk            
          and chair of $712.  After a review of the record, we conclude               
          that petitioners have substantiated the purchase of the desk and            
          chair for use in Mr. Coffman’s home office and that they are                
          entitled to a miscellaneous itemized deduction for $712.   See              
          sec. 67(a).                                                                 
               Section 162(a) allows deductions for all the ordinary and              
          necessary expenses paid or incurred during the taxable year in              
          carrying on any trade or business.  An “ordinary” expense is one            
          that relates to a transaction “of common or frequent occurrence             
          in the type of business involved”, Deputy v. du Pont, 308 U.S.              
          488, 495 (1940), and a “necessary” expense is one that is                   
          “appropriate and helpful” for “the development of the                       
          petitioner’s business”, Welch v. Helvering, 290 U.S. 111, 113               





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