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John Smith is a purchasing agent who purchases grain for various companies. In 2020, the company he previously worked for as a purchasing agent, SUPER
John Smith is a purchasing agent who purchases grain for various companies. In 2020, the company he previously worked for as a purchasing agent, SUPER Grain Co., was bankrupted and had its debts discharged by the Bankruptcy Court. To reestablish his business relationships with former customers and suppliers and to solidify his standing in the industry, John decided to personally pay some of SUPER Grain Co.'s discharged debts. Over the course of three years (20212023), John made substantial payments to SUPER Grain Co.'s former creditors, totaling $200,000.00. In each of these years, he deducted these payments from his income as "ordinary and necessary" business expenses when filing his tax returns. The IRS disallowed these deductions, asserting that the payments were capital expenditures to develop John's reputation and goodwill, not ordinary and necessary business expenses. Analyze the tax treatment of John's payments to SUPER Grain Co.'s creditors after the Bankruptcy was completed and the creditors' debts were legally discharged. Specifically, discuss whether these payments qualify as "ordinary and necessary" business expenses deductible from John's income as a purchasing agent
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