26 U.S.C. § 212

Expenses for production of income

In the case of an individual, there shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year—

(1)

for the production or collection of income;

(2)

for the management, conservation, or maintenance of property held for the production of income; or

(3)

in connection with the determination, collection, or refund of any tax.

( Aug. 16, 1954, ch. 736 , 68A Stat. 69 .)