Robert A. White - Page 10

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          ordinary and necessary for petitioner’s business.  Respondent               
          asserts that petitioner was eligible for reimbursement from DHS             
          for expenses incurred performing his duties.                                
               Section 162 allows deductions for all ordinary and necessary           
          business expenses paid or incurred during the taxable year in               
          carrying on a trade or business.  Performing services as an                 
          employee constitutes a trade or business.  Primuth v.                       
          Commissioner, 54 T.C. 374, 377-378 (1970).  Those expenses that             
          are (1) ordinary and necessary to the taxpayer’s business and (2)           
          paid or incurred in a given year are deductible that year.  Sec.            
          162(a); see sec. 1.162-17(a), Income Tax Regs.  However,                    
          personal, living, or family expenses are not deductible.  See               
          secs. 162(a), 262(a); sec. 1.162-17(a), Income Tax Regs.                    
               Certain categories of expenses must also satisfy the strict            
          substantiation requirements of section 274(d) before those                  
          expenses will be allowed as deductions.  Expenses subject to                
          section 274(d) include travel and meal expenses, as well as                 
          expenses for listed property, such as passenger automobiles,                
          computers, and cellular telephones.  Secs. 274(d), 280F(d)(4).              
          The taxpayer must substantiate the amount, time, place, and                 
          business purpose of the expenditures and must provide adequate              
          records or sufficient evidence to corroborate his own statement.            
          See sec. 274(d); sec. 1.274-5T(c)(1), Temporary Income Tax Regs.,           
          50 Fed. Reg. 46016 (Nov. 6, 1985).  In order to meet the                    

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