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to complete college or university courses. Petitioner enrolled
in the U.C. Extension courses with specific educational
objectives. She testified that she has not seen classes
available elsewhere offering similar courses of study. As
evidenced by several Tax Court cases involving teachers enrolling
in university courses and studying abroad in order to improve
teaching skills, such an expenditure is "normal" for a high
school teacher. See, e.g., Ford v. Commissioner, supra; Weiman
v. Commissioner, T.C. Memo. 1971-92. Professional educators act
on the assumption that further education improves their ability
to use their knowledge effectively. See Ford v. Commissioner,
supra at 1306. Under the particular facts of this case,
petitioner's participation in the U.C. Extension courses resulted
in ordinary business expenditures.
"Necessary" has been construed to mean "appropriate" or
"helpful", not "indispensable" or "required". Id. at 1305-1307.
If there are "reasonably evident business ends to be served, and
the intention to serve them appears adequately from the record",
expenses satisfy the "necessary" requirement. Manischewitz Co.
v. Commissioner, 10 T.C. 1139, 1145 (1948). As discussed, the
U.C. Extension courses improved petitioner's teaching skills.
The expenses associated with a teacher's pursuing further
education that develops her understanding of topics which are
part of the curriculum she teaches in her classroom, helps her
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