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Accordingly, DD is not considered a “qualifying child” within the
meaning of section 24(c). It follows, therefore, that petitioner
is not entitled to a child tax credit under section 24(a) with
respect to DD.
3. Schedule C Expenses
A taxpayer generally may not deduct personal, living, and
family expenses. Sec. 262(a). However, section 162(a) allows a
taxpayer to deduct all ordinary and necessary business expenses
paid or incurred during the taxable year in carrying on any trade
or business. To be “necessary” an expense must be “appropriate
and helpful” to the taxpayer’s business. Welch v. Helvering, 290
U.S. at 113-114. To be “ordinary” the transaction which gives
rise to the expense must be of a common or frequent occurrence in
the type of business involved. Deputy v. Du Pont, 308 U.S. 488,
495 (1940).
Section 6001 and the regulations promulgated thereunder
require taxpayers to maintain records sufficient to permit
verification of income and expenses. As a general rule, if the
trial record provides sufficient evidence that the taxpayer has
incurred a deductible expense, but the taxpayer is unable to
adequately substantiate the precise amount of the deduction to
which he or she is otherwise entitled, the Court may estimate the
amount of the deductible expense, bearing heavily against the
taxpayer whose inexactitude in substantiating the amount of the
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