- 9 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011