-11-
with respect to the disallowance of the deduction for moving
expenses is sustained.
Employee Business Expenses
We now turn our attention to petitioners' deduction for
employee business expenses. Pursuant to section 162(a), a taxpayer
may deduct all ordinary and necessary expenses paid or incurred
during the taxable year in carrying on a trade or business. In
general, an expense is ordinary if it is considered "normal, usual,
or customary" in the context of the particular business out of
which it arose. Deputy v. duPont, 308 U.S. 488, 495-496 (1940).
The term "ordinary" is also used to distinguish currently
deductible items from capital expenditures. Commissioner v.
Tellier, 383 U.S. 687, 689-690 (1966). An expense is necessary if
it is appropriate and helpful to the operation of the taxpayer's
trade or business. Carbine v. Commissioner, 83 T.C. 356, 363
(1984), affd. 777 F.2d 662 (11th Cir. 1985); Heineman v.
Commissioner, 82 T.C. 538, 543 (1984). Only the portion of an
expense that is reasonable in amount is deductible under section
162. United States v. Haskel Engg & Supply Co., 380 F.2d 786, 788-
789 (9th Cir. 1967).
Petitioners deducted $5,020 for membership fees and expenses
in Gull Lake Country Club. Mr. Martin was an active member of the
country club from July to December 1989. Mr. Martin testified that
he joined the country club only because he was "strongly
encouraged" to do so in connection with his employment. He further
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