...reserve for bad debts of financial institutions, for purposes of section 166(c). Section 166 (a) ( 1 ) of the Code provides that there shall be allowed as a deduction any debt that becomes worthless during the taxable year. Section 166(c) of the Code provides that in...

...taxable year 1974 are only 83.3 percent of the total gross receipts for that year. Section 165 (a) of the Code provides that there shall be allowed as a deduction any loss sustained during the taxable year and not compensated for by insurance or otherwise. Section...

...or in kind were made to a local or state welfare agency, an organization described in section 170(c) (1) of the Code, and the gift were made "for exclusively...states that no deduction is allowable under section 162(a) for a contribution or gift by an individual or a corporation if any part thereof is deductible...

...183(b); sec. 1.183-l(b)(l), Income Tax Regs. 4, Deduction of Rental Property Expenses Section 162(a) provides that "there shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business."...

...the year 1967. To be deductible, such an expense must fall within the purview of section 162 2 which provides that "there shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business."...

...to petitioner's employment with the Spivey Co. OPINION KERN, Judge: Section 162 (a) provides in part that "There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including...

...beginning after December 31, 1973. Sec. 2. Background. Section l62(a) of the Internal Revenue Code of 195U provides that there shall be allowed as a deduction all the ordinary and neccct-.ary expenses paid or incurred during the' taxable year in carrying on any trade or business....

...(c)(3). Receipt of such a ruling letter leads, in the ordinary case, to inclusion in 1 Section 170 (a) of the Code provides that "[t]here shall be allowed as a deduction any charitable contribution (as defined in subsection (c)) payment of which is made within the taxable...

...Internal Revenue Code of 1954 defines gross income as all Section 162 of the Code provides, in part, that there shall be allowed as a deduction all the...year in carrying on any trade or business. Section 6012 (a) (2) of the Code provides that returns with respect to income taxes under subtitle A shall...

...compensation for services, fees, commissions, and similar i tens. Section 162(a) of the Code states that there shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business. Paycieut...