Michael P. and Pamela J. Hopkins - Page 16

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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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