Lohrke v. Commissioner, 48 T.C. 679 (1967), is a significant case cited for its opinion which further articulated a much-litigated phrase "ordinary and necessary" business expense in the Tax Code, 26 U.S.C.S. § 162(a). Although it has been distinguished in nine cases, it has been followed by thirteen cases and cited in various treatises. In Lohrke, the Tax Court determined that when the taxpayer paid for expenses that he was not actually obligated to pay, he could still deduct them as an "ordinary and necessary" business expense under 26 U.S.C.S. § 162(a) of the Tax Code.