Ann Jorgensen - Page 16

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          petitioner was able to gain more from her travel experience.  In            
          light of the classes petitioner taught, her role in developing              
          curriculum for the English department, the racial and cultural              
          background of many of her students, and petitioner's                        
          incorporation of tangible knowledge and skills learned in the               
          U.C. Extension courses into the classes she teaches, we find the            
          courses had a direct and proximate relationship in maintaining              
          and improving petitioner's skills as a high school English                  
          teacher and as chair of the English department.                             
               In addition to proving that the U.C. Extension courses                 
          maintained or improved her teaching skills, petitioners must                
          prove that such expenses were "ordinary and necessary" within the           
          meaning of section 162(a).  See Boser v. Commissioner, 77 T.C. at           
          1132; Ford v. Commissioner, 56 T.C. 1300, 1305-1307 (1971), affd.           
          per curiam 487 F.2d 1025 (9th Cir. 1973); Stricker v.                       
          Commissioner, T.C. Memo. 1995-530; McCulloch v. Commissioner,               
          T.C. Memo. 1988-84; Raines v. Commissioner, T.C. Memo. 1983-125;            
          sec. 1.262-1(b)(9), Income Tax Regs.                                        
               "Ordinary" has been defined in the context of section 162(a)           
          as that which is "normal, usual, or customary" in the taxpayer's            
          trade or business.  Deputy v. du Pont, 308 U.S. 488, 495 (1940).            
          The activity which gives rise to the expense must not be one that           
          is rare in the taxpayer's business.  See Welch v. Helvering, 290            
          U.S. at 114; Stricker v. Commissioner, supra.  An activity that             

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