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to the continuation of his employment are deductible. Noland v.
Commissioner, 269 F.2d 108, 111 (4th Cir. 1959), affg. T.C. Memo.
1958-60. Education expenses are considered ordinary and
necessary business expenses if the education maintains or
improves skills required by the taxpayer in his employment, or
meets the express requirements of an employer, imposed as a
condition for the taxpayer's continued employment, status, or
rate of compensation. Sec. 1.162-5(a), Income Tax Regs.
Personal expenses are not deductible. Sec. 262.
Petitioner has not established through his testimony or by
other evidence that the purchase and use of the comic books
maintained or improved his skills required as a high school
teacher. Nor is there any evidence that the expenses were
incurred to meet the express requirements of the school. Thus,
the costs of the comic books are not deductible as education
expenses.
In addition, we are not persuaded that the expenses were
ordinary or necessary in petitioner's trade or business of
earning pay as a school teacher. Although petitioner believed
that he was required to sponsor an extracurricular activity as a
condition of his continued employment, it does not necessarily
follow that the expenses he incurred in doing so were ordinary
and necessary. The comic books may have been helpful to the club
members, but petitioner has not established that they were
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