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involved”, Deputy v. du Pont, 308 U.S. 488, 495 (1940), and a
necessary expense is one that is “appropriate and helpful” for
“the development of the petitioner’s business,” Welch v.
Helvering, 290 U.S. 111, 113 (1933). Personal, family, and
living expenses, on the other hand, generally are not deductible.
Sec. 262(a).
First, we are not convinced that petitioner was engaged in a
trade or business in the year in issue. The primary evidence
that petitioner was engaged in any business at all is
petitioner’s brief and conclusory testimony. The testimony was
unclear, but it seems that petitioner’s contention is that the
Schedule C was filed not for one business, but for two--an
antique clock business which was not identified on the return in
addition to the research and publication business which was
identified. At one point, however, petitioner testified that the
antique clock business was “dead” and that none of the gross
income on the Schedule C was for that business. As for the
$1,875 of income that was reported, he could not provide
sufficient details concerning its source. He testified that this
amount was the income he received from activity such as reviewing
manuscripts and selling textbooks, but could not name the
publishing companies from which the income was received. The
only other evidence which indicates the existence of a business
consists of checks drawn on two bank accounts. The accounts each
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