Joseph B. Campbell - Page 27

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          it is normal, usual, or customary within a particular trade,                
          business, or industry or arises from a transaction “of common or            
          frequent occurrence in the type of business involved.”  Deputy v.           
          du Pont, 308 U.S. 488, 495 (1940).  An expense is necessary if it           
          is appropriate and helpful for the development of the business.             
          See Commissioner v. Lincoln Sav. & Loan Association, supra at               
          353; Commissioner v. Heininger, 320 U.S. 467, 471 (1943).                   
          Section 262(a) disallows deductions for personal, living, or                
          family expenses.  See also sec. 1.162-17(a), Income Tax Regs.               
               Section 162 also allows a taxpayer to deduct ordinary and              
          necessary business expenses in excess of reimbursements from the            
          taxpayer’s employer.  See sec. 1.162-17(b)(3), Income Tax Regs.             
               If the employee’s ordinary and necessary business                      
               expenses exceed the total of the amounts charged                       
               directly or indirectly to the employer and received                    
               from the employer as advances, reimbursements, or                      
               otherwise, and the employee is required to and does                    
               account to his employer for such expenses, the taxpayer                
               may * * * claim a deduction for such excess.  [Id.]                    
               If the taxpayer wishes to secure a deduction for such                  
          excess, he must submit a statement with his return showing:  (1)            
          “The total of any charges paid or borne by the employer and of              
          any other amounts received from the employer for payment of                 
          expenses whether by means of advances, reimbursements or                    
          otherwise”, sec. 1.162-17(b)(3)(i), Income Tax Regs.; and (2)               
          “The nature of his occupation, the number of days away from home            
          on business, and the total amount of ordinary and necessary                 

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