- 14 -
ordinary if it is considered 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). Ordinarily, an
expense is necessary if it is appropriate and helpful to the
operation of the taxpayer's trade or business. See Commissioner
v. Tellier, 383 U.S. 687, 689 (1966); Carbine v. Commissioner, 83
T.C. 356, 363 (1984), affd. 777 F.2d 662 (11th Cir. 1985).
On the record before us, we find that petitioner has failed
to establish (1) that he incurred and paid all of the claimed
Schedule C expenses, (2) that he was engaged in any trade or
business, other than that of being an employee of Wilder and of
Goodfellow, and (3) that any of the claimed Schedule C expenses
are ordinary and necessary to any trade or business in which
petitioner claims to have engaged.
With respect to the depreciation claimed in Schedule C, on
the record before us, we find that petitioner has failed to prove
that any of the properties with respect to which such deprecia-
tion was claimed was used in a trade or business of petitioner or
held by him for the production of income.8 See sec. 167(a).
Based on our examination of the entire record before us, we
find that petitioner has failed to show that he is entitled to
8Assuming arguendo that petitioner had established that
properties on which depreciation was claimed in Schedule C were
used in a trade or business or held for the production of income,
we find on the instant record that petitioner has failed to prove
his respective bases in any such properties. See sec. 167(c).
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