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All of the business travel is assumed to be ordinary and necessary and the accountable plan rules are assumed to be met.
On those returns the firm deducted as an ordinary and necessary business expense litigation costs of $705,647 and $629,834 it had paid on behalf of contingent lee clients whose matters had not been resolved by yearend.
One of the reasons that TEI filed an amicus brief in INDOPCO back in 1991 was to express concern over the possible breadth of the Third Circuit's decision in the case: "If the Third Circuit's definition of a capital expenditure as any expenditure yielding income substantially beyond the taxable year gains currency," the Institute wrote, "then the manifest deductibility of untold ordinary and necessary expenses will be jeopardized.
However, the courts have been much more expansive in their interpretation of the ordinary and necessary requirement.
Companies can deduct travel expenses while employees are working away from home in the pursuit of a trade or business as ordinary and necessary expenses under IRC section 162(a).
Furthermore, National Starch argued that Lincoln Savings specifically rejected looking to the presence of a future benefit to determine whether expenditures were ordinary and necessary.
162 provides for the deduction of ordinary and necessary expenses incurred by a trade or business.
IRC section 162 allows companies to deduct all ordinary and necessary expenses paid or incurred during the tax year in carrying on a trade or business.
One recurring source of that friction is the requirement that proper distinctions be drawn between capital expenditures and deductible ordinary and necessary business expenses.
263(a)) and ordinary and necessary business expenses (Sec.
Therefore, Allen can deduct the deficiency interest to the extent it is an ordinary and necessary business expense.
As a result, we believe the ruling's conclusion is erroneous; machinery reconfiguration costs to accommodate just-in-time techniques are deductible as ordinary and necessary business expenses.