Ragnhild A. Westby - Page 27

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          disbursement on a note (Nov. 16, 1987), and several transfers               
          from account No. 109-070-3, totaling $22,509.69.  Respondent also           
          failed adequately to adjust his calculation for the total amount            
          of rental income, loan repayments, and installment sale income              
          that petitioner received during 1987.  Similar mistakes were made           
          in the bank deposits analysis for 1989.                                     
               Our review confirms that the simplistic bank deposits                  
          analyses prepared and relied upon by respondent to support his              
          restated income adjustments against petitioner for 1987 and 1989            
          are simply not credible.  We conclude, therefore, that                      
          respondent’s determinations that petitioner had unreported                  
          Schedule C income for 1987 and 1989 are erroneous, and we hold              
          that respondent’s determinations of unreported income for 1987              
          and 1989 are not sustained.                                                 
               C.  Schedule C Deductions                                              
                    1.  Applicable Legal Principles                                   
               The only basis asserted by respondent in the notices of                
          deficiency for disallowing petitioner’s Schedule C expenses was             
          petitioner’s alleged failure to establish that the expenses were            
          “paid or incurred during the taxable year” and were “ordinary and           
          necessary to * * * [petitioner’s] business.”  Section 162(a)                
          authorizes a taxpayer to deduct ordinary and necessary business             
          expenses paid or incurred during the taxable year in carrying on            
          a trade or business.  An “ordinary” expense is one incurred in a            






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