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See also Taxation (activity not engaged in for profit) 

Since the first income tax act, the provisions authorizing business deductions have varied only slightly. The Revenue Act of 1913 38 Stat. 167, Section II B allowed as a deduction 'the necessary expenses actually paid in carrying on any business.' By 1918, the present form was fixed, and has so continued. 40 Stat. 1066, Sec. 214(a)(1). No regulation has ever been promulgated which interprets the meaning of 'carrying on a business,' nor any rulings approved by the Secretary of the Treasury -- i.e., Treasury Decisions. Cf. Helvering v. New York Trust Co., 292 U. S. 455, 292 U. S. 467-468. See also Biddle v. Commissioner, 302 U. S. 573, 302 U. S. 582. Cf. Estate of Sanford v. Commissioner, 308 U. S. 39, 308 U. S. 52. But see Helvering v. Bliss, 293 U. S. 144, 293 U. S. 151, and McFeely v. Commissioner, 296 U. S. 102, 296 U. S. 108. 

To determine whether the activities of a taxpayer are 'carrying on a business' requires an examination of the facts in each case. All expenses of every business transaction are not deductible. Only those ...

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