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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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