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items of clothing. Petitioners required their children to pay
for such items because they wanted to instill a strong work ethic
in them.
Petitioners reported gross receipts of $4,900 for the dog-
breeding business on a separate Schedule C. Petitioners claimed
expense deductions for the business totaling $16,007, of which
amount $12,750 represented payments to their daughters. There is
no indication petitioners issued a Form W-2 to any of their
daughters. Respondent disallowed $12,295 of the claimed wage
expense deduction. It is not clear why respondent allowed the
remaining $455.
Discussion
In general, the Commissioner’s determinations set forth in a
notice of deficiency are presumed correct, and the taxpayer bears
the burden of showing that the determinations are in error. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Pursuant
to section 7491(a), the burden of proof as to factual matters
shifts to respondent under certain circumstances. We decide this
case without regard to the burden of proof. Accordingly, we need
not decide whether section 7491(a) applies in this case.5
A taxpayer who is carrying on a trade or business generally
may deduct ordinary and necessary expenses paid or incurred in
5 Petitioners filed a motion to shift the burden of proof to
respondent. Because the burden of proof does not affect the
outcome of this case, that motion was denied.
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