Les B. Martin and Millie A. Martin - Page 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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