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satisfies the requirements for deductibility under section 162 is
a question of fact. See Commissioner v. Heininger, 320 U.S. 467,
475 (1943). In general, an expense is ordinary if it is consid-
ered 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 (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).
With respect to the deductions for 1993 totaling $7,902
claimed in Schedule C for “Repair parts”, respondent concedes
that petitioners are entitled to deduct $5,214 of those claimed
expenses. However, respondent contends that petitioners are not
entitled to deduct the balance (i.e., $2,688) of those claimed
Schedule C expenses because they have not shown that such ex-
penses are ordinary and necessary expenses paid during 1993 in
carrying on Mr. Petty’s truck service business. Of the $2,688 of
claimed Schedule C expenses for “Repair parts” that are at issue,
petitioners have shown that during 1993 they paid only $183.59
of such claimed expenses.6 We find on the instant record that
6Petitioners contend that the entire amount of the $183.59
of Schedule C expenses at issue for 1993 that we have found they
paid during that year relates to, and is deductible as, “Repair
parts”. On the record presented, we reject that contention. For
(continued...)
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