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within the meaning of section 162(a), courts generally have
focused on the existence of a reasonably proximate relationship
between the expense and the taxpayer’s business and the primary
motive or purpose for incurring it. E.g., Greenspon v. Commis-
sioner, 229 F.2d 947, 954-955 (8th Cir. 1956), affg. on this
issue 23 T.C. 138 (1954); Henry v. Commissioner, 36 T.C. 879, 884
(1961); Larrabee v. Commissioner, 33 T.C. 838, 841-843 (1960).
In general, where an expense is primarily associated with profit-
motivated purposes, and personal benefit can be said to be
distinctly secondary and incidental, it may be deducted under
section 162(a). E.g., Intl. Artists, Ltd. v. Commissioner, 55
T.C. 94, 104 (1970); Sanitary Farms Dairy, Inc. v. Commissioner,
25 T.C. 463, 467-468 (1955); Rodgers Dairy Co. v. Commissioner,
14 T.C. 66, 73 (1950). Conversely, if an expense is primarily
motivated by personal considerations, no deduction for it will be
allowed under section 162(a). E.g., Henry v. Commissioner,
supra; Larrabee v. Commissioner, supra. A taxpayer’s general
statement that his or her expenses were incurred in pursuit of a
trade or business is not sufficient to establish that the ex-
penses had a reasonably direct relationship to any such trade or
business. Ferrer v. Commissioner, 50 T.C. 177, 185 (1968), affd.
per curiam 409 F.2d 1359 (2d Cir. 1969).
Even if “An expenditure may be, by its nature, ordinary and
necessary, * * * at the same time it may be unreasonable in
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