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if an expenditure is motivated primarily by personal
considerations, no deduction generally will be allowed. See
Henry v. Commissioner, 36 T.C. 879, 884 (1961).
An individual may engage in the trade or business of
rendering services as an employee. See O’Malley v. Commissioner,
91 T.C. 352, 363-364 (1988), affd. 972 F.2d 150 (7th Cir. 1992);
Primuth v. Commissioner, 54 T.C. 374, 377 (1970). Consequently,
an employee’s business expenses may be deductible under section
162. See Johnson v. Commissioner, 115 T.C. 210, 217 (2000);
O’Malley v. Commissioner, supra; Primuth v. Commissioner, supra
at 377-378.
Deductions are strictly a matter of legislative grace, and a
taxpayer must meet the specific statutory requirements for any
deduction claimed. See INDOPCO, Inc. v. Commissioner, 503 U.S.
79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435,
440 (1934). Taxpayers are required to maintain records
sufficient to substantiate their claimed deductions. See sec.
6001; sec. 1.6001-1(a), Income Tax Regs. Under certain
circumstances, if claimed deductions are not adequately
substantiated, we may estimate them, provided we are convinced
that the taxpayer has incurred such expenses and we have a basis
upon which to make an estimate. See Cohan v. Commissioner, 39
F.2d 540, 543-544 (2d Cir. 1930); Vanicek v. Commissioner, 85
T.C. 731, 743 (1985).
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