Sue Taylor - Page 30

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         presumption that respondent’s deficiency determination with                  
         respect to her income from that source was correct.16                        
              G.   Deductions                                                         
              Section 162 generally allows a taxpayer to deduct “all the              
         ordinary and necessary expenses paid or incurred during the                  
         taxable year in carrying on a trade or business”.  An “ordinary”             
         expense is one that is normal, usual, or customary in the type of            
         business involved.  See Deputy v. Du Pont, 308 U.S. 488, 495                 
         (1940).  A “necessary” expense is one that is “appropriate and               
         helpful” to the taxpayer’s business.  Welch v. Helvering, 290                
         U.S. 111, 113 (1933).                                                        
              Deductions are a matter of legislative grace.  New Colonial             
         Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).  Taxpayers have              
         the burden to show they are entitled to any deduction claimed on             
         their returns, and they must be able to point to some particular             
         statute and demonstrate that they come within its terms.  Deputy             
         v. Du Pont, supra at 493; New Colonial Ice Co. v. Helvering,                 
         supra.  Where taxpayers do not substantiate their claimed                    
         deductions, the Commissioner is not arbitrary or unreasonable in             
         determining that the claimed deductions should be denied.                    
         Roberts v. Commissioner, 62 T.C. 834, 837, (1974).                           


               16 On petitioner’s 1999 Form 1040, Schedule C, she reported            
          income from the business, “Natures Herbs”, admitting her                    
          relationship with this business during that year.                           






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