In regard to the statutory scheme for determining deductibility, a taxpayer may deduct an expense only if it is "specifically" identified (e.g., interest) as deductible in the Code.For example, advertising expense of a business would not be deductible unless a code provision specifically indicated that advertising expense is deductible.

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The tax code allows for the deduction of ordinary and necessary business expenses under Section 162 of the Internal Revenue Code, without requiring each type of expense to be specifically identified. Advertising expenses are generally considered to be ordinary and necessary expenses of carrying on a trade or business and are therefore deductible.

In Regard to the Statutory Scheme for Determining Deductibility, a Taxpayer