Adell Maxie, Jr. - Page 8




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                    tax for the year at issue.  Petitioner presented no evidence                                                                                           
                    establishing that the $9,363 of unreported income is not subject                                                                                       
                    to self-employment tax.  Accordingly, we hold that petitioner is                                                                                       
                    liable for self-employment tax on the unreported income.                                                                                               
                    Respondent is sustained on this issue.                                                                                                                 
                    3.  Schedule C--Business Expense Deductions                                                                                                            
                              Deductions are a matter of legislative grace, and the                                                                                        
                    taxpayer bears the burden of proving the entitlement to any                                                                                            
                    deduction claimed.  INDOPCO, Inc. v. Commissioner, 503 U.S. 79,                                                                                        
                    84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440                                                                                        
                    (1934).  A taxpayer is required to maintain records sufficient to                                                                                      
                    establish the amount of his or her deductions.  Sec. 6001; sec.                                                                                        
                    1.6001-1(a), (e), Income Tax Regs.                                                                                                                     
                              Section 162(a) allows a taxpayer to deduct ordinary and                                                                                      
                    necessary business expenses paid or incurred during the taxable                                                                                        
                    year in carrying on any trade or business.  To be “ordinary” the                                                                                       
                    transaction which gives rise to the expense must be of a common                                                                                        
                    or frequent occurrence in the type of business involved.  Deputy                                                                                       
                    v. Du Pont, 308 U.S. 488, 495 (1940).  To be “necessary” an                                                                                            
                    expense must be “appropriate and helpful” to the taxpayer’s                                                                                            
                    business.  Welch v. Helvering, supra at 113. Additionally, the                                                                                         
                    expenditure must be “directly connected with or pertaining to the                                                                                      
                    taxpayer’s trade or business”.  Sec. 1.162-1(a), Income Tax Regs.                                                                                      
                    Pursuant to section 262(a), no deduction is allowed for personal,                                                                                      





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