- 10 - Respondent also determined that petitioner was liable for that taxable year for the accuracy-related penalty under section 6662(a). OPINION Petitioner bears the burden of proving that the determina- tions in the notice are erroneous. See Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Claimed Royalty Expense Deduction Petitioner contends that it is entitled under section 162(a) to deduct for the year at issue the royalty expense claimed in the Form 1120 that it filed for that year. Respondent counters that petitioner has failed to establish that it satisfies the requirements of section 162(a). Respondent also contends that petitioner has failed to prove that it satisfies the all events test with respect to the claimed royalty expense. See sec. 461(a) and (h). On the record before us, we agree with respon- dent. Section 162(a) allows a taxpayer to deduct all the ordinary and necessary expenses that such taxpayer paid or incurred during the taxable year in carrying on such taxpayer’s trade or busi- ness. Deductions are strictly a matter of legislative grace, and a taxpayer must meet the specific statutory requirements for any deduction claimed. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). The determination of whether an expenditurePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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