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case does not shift to respondent.
Employee Business Expenses
Section 162 generally allows a deduction for ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business. Generally, no deduction is
allowed for personal, living, or family expenses. See sec. 262.
An employee's trade or business is earning his compensation, and
generally only the expenses that are related to the continuation
of his employment are deductible. Noland v. Commissioner, 269
F.2d 108, 111 (4th Cir. 1959), affg. T.C. Memo. 1958-60.
Petitioner must show that the business expenses he claimed
were incurred primarily for business rather than for personal
reasons. See Rule 142(a). To show that an expense was not
personal, petitioner must prove that the expense was incurred
primarily to benefit his business, the continuation of his
employment, and that there was a proximate relationship between
the claimed expense and his business. Walliser v. Commissioner,
72 T.C. 433, 437 (1979).
Where a taxpayer has established that he incurred a trade or
business expense, failure to prove the exact amount of the
otherwise deductible item may not always be fatal. Generally,
unless prevented by section 274, the Court may estimate the
amount of such an expense and allow the deduction to that extent.
See Finley v. Commissioner, 255 F.2d 128, 133 (10th Cir. 1958),
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