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business expenses they claimed on their return. Petitioners
conceded in the stipulation of settled issues most of the
employee business expenses claimed on their return. They
therefore bear the burden of proving they are entitled to a
greater deduction than that allowed by respondent.
Taxpayers may deduct ordinary and necessary expenses paid or
incurred during the taxable year in carrying on a trade or
business. Sec. 162(a). The term “ordinary and necessary
business expenses” means only those expenses that are ordinary
and necessary and are directly attributable to the trade or
business. Sec. 1.162-17(a), Income Tax Regs. The term does not
include personal, living, or family expenses. Id.; see sec.
262(a). Simply because an expense would not have been incurred
but for the taxpayer’s engaging in a trade or business is
insufficient to allow a deduction. The nature of the expense
must not be personal or otherwise nondeductible. Drake v.
Commissioner, 52 T.C. 842, 844 (1969).
There are many expenses that are helpful, even essential, to
one's business, but which are not deductible in our tax system.
See Carroll v. Commissioner, 51 T.C. 213, 215 (1968), affd. 418
F.2d 91 (7th Cir. 1969). Expenses of driving to and from work,
for example, are not deductible. Sec. 1.162-2(e), Income Tax
Regs. Expenses for clothing worn in a taxpayer's trade or
business, and the costs of laundering the clothing, are not
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