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the use of, inter alia, a State, possession of the United States,
or any political subdivision of the foregoing. Sec. 170(c)(1).
On their joint 2002 Federal income tax return, petitioners
deducted charitable cash contributions of $5,456. Respondent
initially allowed $2,385 of that amount and later conceded an
additional $2,825, leaving $246 in dispute. At trial,
petitioners introduced a copy of a check for $25 to the City of
Carson. The face of the check bears no indication that the $25
represents a contribution or gift, and petitioners offered no
testimony with respect to this item. Accordingly, respondent’s
determination is sustained to the extent of $246.
B. Other Expenses
Section 162(a) generally allows a deduction for ordinary and
necessary business expenses. To qualify as an allowable
deduction under section 162(a), an item must be: (1) Paid or
incurred during the taxable year; (2) for carrying on any trade
or business; (3) an expense; (4) a necessary expense; and (5) an
ordinary expense. Commissioner v. Lincoln Sav. & Loan
Association, 403 U.S. 345, 352 (1971); FMR Corp. & Subs. v.
Commissioner, 110 T.C. 402, 414 (1998).
Petitioners attached to their return a Schedule C, Profit or
Loss From Business, for a business described as real estate
consulting. Petitioners deducted $29,132 of other expenses on
Schedule C, consisting of items such as supplies expense, tax
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