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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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