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Deputy v. du Pont, 308 U.S. 488, 495 (1940). The expense need
not be one common for the particular taxpayer but, instead, be
one that is not rare in the taxpayer's business. See Welch v.
Helvering, 290 U.S. 111, 114 (1933). Enrolling in a sales course
to improve sales skills is a "normal" expenditure for a salesman.
In this instance, however, petitioner left his home and his
business for over 20 days to attend a sales course that consisted
of his reading a 193-page book. The lack of intensity in study,
coupled with the length of time away from his business, is
certainly not ordinary in the sale of meat and seafood.
"Necessary" has been construed to mean "appropriate" or
"helpful", not "indispensable" or "required". Ford v.
Commissioner, 56 T.C. 1300, 1306 (1971), affd. 487 F.2d 1025 (9th
Cir. 1973). It is sufficient if "there are also reasonably
evident business ends to be served, and the intention to serve
them appears adequately from the record." B. Manischewitz Co. v.
Commissioner, 10 T.C. 1139, 1145 (1948). Sales training is an
"appropriate" expenditure for a salesman. From the record, we
conclude that petitioner had an intention to serve his business
when he participated in the Big League Sales Course. Inherent in
the concept of "necessary", however, is that an expenditure must
be reasonable in relation to its purpose. To the extent that an
expenditure is not reasonable, it is not necessary. An
expenditure may be, by its nature, ordinary and necessary, but at
the same time it may be unreasonable in amount. United States v.
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