Ronna Joan Robertson - Page 9




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          registered in petitioner’s name (the 1986 Pontiac and the 1974              
          Pontiac).  Thus, only the fees paid for the 1986 Pontiac ($131 in           
          1993 and $112 in 1994) and the 1974 Pontiac ($50 in 1993 and $50            
          in 1994) may be allowed as deductions by petitioner.                        
          Accordingly, petitioner is entitled to deductions of $181 and               
          $162 for the 1993 and 1994 tax years, respectively, for personal            
          property taxes.                                                             
               D.  Automobile Sales License                                           
               Section 162(a) generally allows a taxpayer to deduct all               
          ordinary and necessary expenses incurred during the taxable year            
          in carrying on a trade or business.  An expense is ordinary if it           
          is considered to be “normal, usual, or customary” in the context            
          of the particular business out of which it arose.  See Deputy v.            
          du Pont, 308 U.S. 488, 495-496 (1940).  A taxpayer’s general                
          statement that his or her expenses were incurred in pursuit of a            
          trade or business normally is not sufficient to establish that              
          the expenses had a reasonably direct relationship to that trade             
          or business.  See Ferrer v. Commissioner, 50 T.C. 177, 185                  
          (1968), affd. per curiam 409 F.2d 1359 (2d Cir. 1969).                      
               During the trial, petitioner alluded to the fact that she              
          worked part-time for a used car dealer.  Petitioner contends that           
          she is therefore entitled to deduct the $93 that she paid to the            
          California DMV for an automobile sales license.  Petitioner,                
          however, has failed to present any evidence establishing that a             






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